Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
, see all updates

Ownership and income tax: legal background: ownership - beneficial owner

The beneficial owner is the person for whose benefit the property is held. It is distinguished from the person in whose name the property is held (the legal owner).

‘[beneficial ownership] means ownership for your own benefit as opposed to ownership as trustee for another.’ (J Sainsbury plc v O’Connor 64 TC 208)

The beneficial owner is sometimes referred to as having a ‘beneficial interest’ in the property.