Commentary

I3.366 Fall in value relief—close companies

IHT, trusts and estates

I3.366 Fall in value relief—close companies

I3.366 Fall in value relief—close companies

There is provision1 for cases where the property transferred by the lifetime transfer (see I3.361) consists of shares or securities2 in a close company and at any time after the transfer and before the relevant date there is a relevant transaction in relation to the shares. For this purpose 'relevant transaction' means3 a transaction which is:

  1.  

    •     a transfer of value made by the company, or

  2.  

    •     an alteration in unquoted share or loan capital of the company or an alteration in any rights attaching to unquoted shares in or debentures of the company.

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