Commentary

I1.536 Apportionment of close company transfers

IHT, trusts and estates

I1.536 Apportionment of close company transfers

I1.536 Apportionment of close company transfers

A transfer of value is a disposition by a person, and person here can include a company (see I3.113). Chargeable transfers, however, are (non-exempt) transfers made by individuals (see I3.102). This apparent paradox is explained by the fact that there are specific rules for apportioning a transfer of value made by a close company to its participators1 (see I6.121–I6.129). The apportionment is according to the rights and interests of the participators (see I6.124), and then IHT is charged as if each participator had made a transfer of value of the amount apportioned to him,

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