Assets held for another by a nominee or bare trustee are treated as if they are vested in the person for whom the assets are held: the beneficiary. The acts of the nominee or trustee in relation to those assets are treated as the acts of the beneficiary. For CGT purposes, therefore, a bare trust is treated as being transparent and any capital gains or losses of the bare trust are treated as those of the person who is entitled to the underlying assets of the trust.

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