The HMRC rubric states that "to benefit as a couple, you need to earn less than your partner and have an income of £11,850 or less. Your partner’s income must be between £11,851 and £46,350 (£43,430 in Scotland) for you to be eligible". I have a client couple who satistied those conditions in 2016/17, except that for the husband, there was a (one-off) Capital Gain, so that the total Income plus Taxable Capital Gain did exceed £46,350, and they live in England. Can the wife transfer one-tenth of her personal allowance to the husband under these circumstances? The Capital Gain, of course, is taxed partly at 18% and partly at 28%. Many thanks!