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Since the introduction of capital gains tax it has been a contentious issue whether capital gains tax would arise in circumstances where a testator releases a debtor from a debt owed by the debtor to the testator or where the testator would bequeath the subject matter of the debt to the debtor resulting in potential set-off or confusio.

In the 2013 Budget Review, which was released on 27 February 2013, specific mention was made that a research project is underway in which consideration is being given to a unified treatment of dividend cessions and manufactured dividends.