Commentary

I6.121 Introduction to transfers by close companies

IHT, trusts and estates

I6.121 Introduction to transfers by close companies

Transfers of value by close companies

I6.121 Introduction to transfers by close companies

IHTA 1984, s 94 deals with the situation where an individual (or a group of individuals) exercises control over a close company and uses it to pass value to an intended beneficiary. This is a transaction which, but for IHTA 1984, s 94, could not give rise to a chargeable transfer for IHT purposes (although a charge to CGT might also arise1 (value shifting — see C1.335). Companies as well as individuals can make transfers of value, but chargeable transfers can only be made by individuals

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial