Commentary

I6.130 Transfers by close companies examples

IHT, trusts and estates

I6.130 Transfers by close companies examples

I6.130 Transfers by close companies examples

Example 1—simple apportionment

The issued share capital of X Ltd, a company incorporated and resident outside the UK, comprises 1,000 ordinary £1 shares, held as follows:

750 by A

200 by B

50 by C.

X Ltd sells premises in London, valued at £100,000, to A for £50,000 on 1 July 2018. At that time, they have all made cumulative gross chargeable transfers in excess of £325,000 in the preceding seven years. Only B has not then used his 2018/19 annual exemption.

X Ltd has made a transfer of value of £50,000. Tax in respect of that transfer is computed

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