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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Property held jointly by married couples or civil partners - The 50/50 rule: income from jointly held shares in a close company

From 6 April 2004, the 50/50 rule does not apply to income distributions arising from shares or securities held in a close company. Broadly, a close company is a company controlled by no more than five people.

Where a married couple or civil partners hold shares in a close company in joint names, each spouse or civil partner is taxable in proportion to their entitlement. For example, if civil partner A is entitled to 90% of the jointly held shares, and civil partner B is entitled to 10%, civil partner A is taxable on 90% of the income, and civil partner B is taxable on 10%. See however TSEM9824.