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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Bare trusts: absolute entitlement

The primary concept employed is that of `absolute entitlement as against the trustee’, as defined in Section 60(2). Broadly, a person is so entitled where

  1. the trustee has no control over the property except with the permission of that person, or
  2. that person can take complete control over the property either immediately or on giving due notice to the trustee.