Commentary

I6.122 The transfer of value by close companies

IHT, trusts and estates

I6.122 The transfer of value by close companies

I6.122 The transfer of value by close companies

For IHTA 1984, s 94 to apply, the close company in question must make a transfer of value1. Whether or not a disposition made by a close company constitutes a transfer of value must be determined according to the general rules of IHT (see Division I3.1).

Therefore, none of the following dispositions are normally chargeable dispositions under that section:

  1.  

    •     a disposition of excluded property2 (see I3.114).

  2.  

    However it should be noted that some excluded property categories relate only to property owned by individuals and therefore do not include property owned by companies

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