Commentary

C2.225 Income tax on apportioned income of close companies

Capital gains tax
Capital gains tax | Commentary

C2.225 Income tax on apportioned income of close companies

Capital gains tax | Commentary

Miscellaneous deductions

C2.225 Income tax on apportioned income of close companies

When the excess relevant income of a close company1 for an accounting period beginning before 1 April 1989 was apportioned2 among its participators3, they were charged4 to income tax on the amount of income apportioned to them. When a person has been so charged and then disposes of any shares to which the apportionment related, the amount of income tax paid by him is deductible in the capital gains computation on the disposal5. However, where an actual distribution of the apportioned income subsequently took place (and thus6 escaped

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