Commentary

I10.114 Close companies

IHT, trusts and estates

I10.114 Close companies

I10.114 Close companies

Where a close company makes a transfer of value, it is the company which is primarily liable for payment of IHT1, though the value transferred will be apportioned among the participators. If the IHT has not been paid by the due date then HMRC can recover tax from2:

  1.  

    (a)     any person to whom any amounts have been apportioned under IHTA 1984, ss 94 or 99, but only for the IHT corresponding proportionately to the part of the transfer apportioned to him3

  2.  

    (b)     any individual (whether a person mentioned in (a) above or not) the value of whose

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