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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Bare trusts: introduction

Where there is a bare trust for CGT purposes we treat the persons absolutely entitled as if they owned the property. We disregard the trustees’ legal ownership. There is an example in CG34362 showing the tax treatment of such a case. It is possible for a trust to be partly bare. This generally happens where one beneficiary has become entitled to a share of the property, but nothing has yet been distributed.