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HMRC internal manual

Capital Gains Manual

Disposal of interests in settlements

An interest under a bare trust, for instance that of a tenant in common, see CG70500+, is not an interest in a settlement, see Harthan v Mason, 53TC272. This is because the property is not settled property and therefore the trustees are not chargeable in respect of it, see CG34300+. Instead a disposal by the beneficiary is treated as a disposal of the underlying asset.