Commentary

C2.721 Assets transferred to close companies

Capital gains tax
Capital gains tax | Commentary

C2.721 Assets transferred to close companies

Capital gains tax | Commentary

C2.721 Assets transferred to close companies

In the absence of any special provisions, a controlling shareholder in a close company could transfer assets to that company and, provided he has owned shares since before 7 April 1965, he or any other substantial shareholder could effectively have the time apportionment rules applied to the gain attributable to those assets, as reflected in the value of shares subsequently disposed of.

Accordingly, where:

  1.  

    •     any of the persons having control1 of a close company2 (or any person who is connected3 with a person having control of a close company), has transferred assets to the

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