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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