Commentary

I6.102 Definition of a close company for IHT purposes

IHT, trusts and estates

I6.102 Definition of a close company for IHT purposes

I6.102 Definition of a close company for IHT purposes

A company is a close company for the purposes of IHTA 1984, ss 94–102 (Pt IV) if it is a close company for the purposes of the Corporation Tax Acts (as defined at D3.102), or would be such but for being resident outside the UK1.

Broadly, a company is close if:

  1.  

    •     it is under the control of five or less participators (or any number of participators if those participators are directors), or

  2.  

    •     more than half the assets of which would be distributed to five or less participators (or to participators

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