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HMRC internal manual

Capital Gains Manual

Bare trusts: pooling of shares etc

Shares or securities disposed of by a `bare trustee’, and any of the same `class’, see CG50203, remaining in his possession in the same trust, together with any of the same `class’ held at the time of the disposal by the person for whom he acts as `bare trustee’, constitute a `pool’, see CG50520 for the purpose of computing the gain on the disposal by the trustee.

CG24000+ deal with the special treatment of Lloyd’s underwriters and assets held in particular Lloyd’s funds.