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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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Ownership and income tax: Specific types of property: bank and building society accounts: example 9: joint names - resulting trust

A provided capital of £250,000 when opening a bank account in joint names with his brother B.

A and B say that the interest on the account should be taxed on each of them equally.

The evidence submitted showed that A was out of the country for frequent and prolonged periods, and his brother B had been named as joint account holder to enable him to operate the account while A was abroad.

The arrangement is purely administrative and confers no beneficial interest on the brother B.

A presumed resulting trust arises (TSEM9600) and is not rebutted by a counter-presumption (TSEM9630), for example evidence that A intended making a gift of any of the capital to B.

A is taxable on all the interest.