IHTM14852 - Transfers by close companies: transfers of value
When a close company makes a transfer of value, you will charge tax as if
- each individual participator had made a transfer of
- the amount apportioned to them
by reference to
- their rights and interests in the company
- immediately before the transfer.
Ask SAV to report the net amount which requires to be grossed up
for each relevant participator.
Review the separate charging provisions in the manual. (
IHTM04068)
