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HMRC internal manual

Capital Gains Manual

Bare trusts: computations: bare trusts and nominees


In the case of bare trusts, gains should be computed and assessments made as if the property were vested in the beneficiary and all the trustee’s acts were his acts: the trustee, and the existence of the trust, should therefore be ignored. This applies to nominees also, see the example in CG34362.

Where there are two or more beneficial owners of property held by a `bare trustee’ and there has been no agreed appropriation of the property, no one of the beneficial owners is strictly entitled to any particular asset. It follows that any assets which are disposed of by the trustees should be treated as having been disposed of by the beneficial owners in accordance with their proportionate shares in the property and that chargeable gains and allowable losses accrue directly to the beneficial owners accordingly.