Commentary

I1.537 Alterations in unquoted securities of close companies

IHT, trusts and estates

I1.537 Alterations in unquoted securities of close companies

I1.537 Alterations in unquoted securities of close companies

Alterations in the unquoted share or loan capital of a close company or alteration or extinguishment of rights attaching to unquoted shares or debentures of it, are treated as dispositions by the participators1 (see I6.111). Whether and to what extent there is a transfer of value is determined on ordinary principles (see I1.503 above), ie it has to be determined whether the alteration was a commercial transaction and whether the value of any participator's estate was diminished by it. The point of treating such alterations as dispositions is that, without this express

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