The passing of a resolution to wind up a company or the appointment of a liquidator, administrator or receiver does not in itself give rise to a disposal for capital gains purposes, either by the shareholder (in respect of the shares in the company1) or by the company (in respect of its assets2).
For capital gains purposes the assets are still deemed to belong to the company, and even where the company's assets are vested in a liquidator, they are still regarded as if they were vested in the company3. Hence a liquidator is treated for all capital gains tax purposes as a nominee or bare trustee for the company within TCGA 1992, s 60. A company is not treated
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 16:57