Commentary

I11.544 Company purchase of own shares to facilitate payment of IHT

IHT, trusts and estates

I11.544 Company purchase of own shares to facilitate payment of IHT

I11.544 Company purchase of own shares to facilitate payment of IHT

A payment by an unquoted1 trading2 company for the redemption, repayment or purchase of its own shares does not rank as a taxable distribution for corporation tax purposes if3:

  1.  

    •     substantially the whole of the money (apart from any sum applied in paying capital gains tax in respect of the disposal of shares to the company) is applied in discharge of the recipients' liability for IHT charged on a death, and

  2.  

    •     it is so applied within two years of the death, and

  3.  

    •     the IHT so paid could

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