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HMRC internal manual

Trusts, Settlements and Estates Manual

Ownership and income tax: Specific types of property: shares: example 8: joint names of civil partners - 50/50 rule applies

A and B, civil partners who live together, hold shares in Z plc in their joint names. A provided all the funds to purchase the shares. A resulting trust to A would otherwise apply (TSEM9600), but the specific tax legislation on ITA/S836 provides that A and B are taxable 50/50 on the income (TSEM9814).

The shares are not in a close company (TSEM9822), so S836 does not exclude them.