Where the PRs hold an asset as bare trustees, any disposal of the asset is a disposal by the beneficiary in respect of whom the asset is held, not the PRs; thus, the CGT rates applicable to any capital gain are those applicable to that of the beneficiary not the PRs qua bare trustees. Where the beneficiary is an individual, the rates applying are 10%/20% or 18%/28%, with a full annual exempt amount being available each tax year.

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