357-150 The creation of a settlement: general considerations
A transfer of property into settlement is a disposal for capital gains tax purposes. This is the case even where the transferor is a trustee of or beneficiary under the settlement (see ¶357-175). As the settlor and trustees are connected persons (see ¶357-050), the transfer will be deemed to be made at market value (see TCGA 1992, s. 17(1), 18(1), (2) and ¶518-900).
Such transfer will be a disposal for capital gains tax purposes irrespective of whether the transfer is revocable or irrevocable.