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HMRC internal manual

Trusts, Settlements and Estates Manual

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HM Revenue & Customs
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Ownership and income tax: Specific types of property: shares: example 5: joint names - siblings

A and B, brother and sister, hold shares in company Y in their joint names. A provided 30% of the purchase price, and B 70%. They claim to be taxed 50/50.

The 50/50 rule (TSEM9814) does not apply because the property is not held in the joint names of husband and wife or civil partners.

The general principles apply. A resulting trust arises such that A is taxable on 30% of the dividends and B on 70%.