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Commentary

I1.5125 Transfers by close companies

IHT, trusts and estates

A transfer of value can be made by a company as well as an individual, however a transfer by a company is not a chargeable transfer. Without an anti-avoidance rule, a close company could make a disposition so that there is a loss to the company, such as a transfer at undervalue to a shareholder. Therefore there are anti-avoidance rules to apportion close

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