Commentary

I5.230 Close companies—alterations in rights attaching to shares: QIIPs

IHT, trusts and estates

I5.230 Close companies—alterations in rights attaching to shares: QIIPs

I5.230 Close companies—alterations in rights attaching to shares: QIIPs

Where there is an alteration before 22 March 206 (including extinguishment1) in either:

  1.  

    •     a close company's share or loan capital (where such capital is not quoted), or

  2.  

    •     the rights attached to shares or debentures in an unquoted close company

and

  1.  

    •     the participators include trustees of a settlement

  2.  

    •     there would be a transfer of value by the trustees if they were beneficially entitled (see I6.111), and

  3.  

    •     an individual is beneficially entitled to an interest in possession under the settlement in the shares or securities,

the alteration is treated

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