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HMRC internal manual

Trusts, Settlements and Estates Manual

Ownership and income tax: implied trust: constructive trust - evidence

If taxpayers wish to argue constructive trust, you should ask for a full and detailed account of those facts together with all the relevant evidence, as if the claimant were presenting the claim to a court of law. Unless the case is sufficiently strong that you think it would be upheld by the courts, you should reject the claim.

While you may reject a ‘constructive trust’ claim, do not accept a ‘constructive trust’ claim in the income tax context without consulting HMRC Trusts & Estates Technical Edinburgh.