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Capital gains made by personal representatives

When a person dies, the assets in the deceased’s estate are deemed to be acquired by the personal representatives (PRs) for a consideration equal to their market value at the date of death. See the Deceased’s capital gains tax position guidance note for a fuller explanation of which assets are included in the tax-free uplift on death.

The PRs are treated for CGT purposes as being a single and continuing body of persons, which has the same residence and domicile that the deceased had at the date of death. This determination of the PRs’ residence and domicile is slightly different from that which applies for income tax purposes, for which the PRs’ residence may be determined by their own residence status as individuals. See the Income tax during administration guidance note.

If estate assets are sold by the PRs, the base cost, or acquisition value, for capital gains tax purposes is the