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HMRC internal manual

Capital Gains Manual

Bare trusts: examples: partnerships

It is common for partnership assets, for example land, to be held by two to four (the statutory maximum) of the partners as trustees for all the partners. The existence of the trust may cause confusion unless it is appreciated that it is a bare trust arising out of the particular legal requirements. However it may be necessary to consider the precise terms of the trust. The asset may not belong to the partnership as a whole but to individual partners. See generally CG27000.