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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Bare trusts: main provision


In certain cases we treat property held by trustees as if it belonged to the beneficiaries directly, see TCGA92/S60 (1). The trustee, for CGT purposes, is disregarded. The simplest case covered by the provision is where one person holds property for another absolutely (that is, as nominee or bare trustee) but Section 60 expressly covers a class of trusts wider than the `bare trust’ of general law.