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HMRC internal manual

Capital Gains Manual

Bare trusts: unincorporated associations

An unincorporated association cannot hold land directly, except, possibly, where it hasbeen created by statute. The land must be held by trustees on its behalf. The trustees arebare trustees for the unincorporated association, which is therefore liable to CorporationTax on the gain. See CTM00520 and Worthing RFC v CIR, 60TC487.