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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: shares: example 6: joint names - more than two names

A, B and C, hold shares in company Z in their joint names. A and B are a married couple. C is B’s brother. Each of them provided one third of the purchase price of the shares.

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 only.

The general principles apply. A resulting trust arises such that A, B and C are taxable on one third of the dividends each.