HMRC have updated their short page on this topic in the Capital Gains manual at CG 37511. The amended wording now reads as follows:
“The principle of Crowe v Appleby does not apply to land in Northern Ireland or the Republic of Ireland, because in both countries the beneficiary could call upon the trustees to convey to him or her an undivided share in the property.”
https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg37551
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Written for accountants and other tax advisers at an intermediate level, Capital Gains Tax is built firmly on a foundation of statutory rules and case law principles. It is illustrated throughout with practical examples, and most chapters include a summary of pitfalls and planning points.
