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Home / Simons-Taxes /IHT, trusts and estates /Part I10 Liability and incidence /Division I10.1 Liability /Liability rules / I10.114 Close companies

I10.114 Close companies

IHT, trusts and estates

Where a close company makes a transfer of value, it is the company which is primarily liable for payment of IHT¹, even though the value transferred will be apportioned among the participators. If the IHT has not been paid by the due date then HMRC can recover tax

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B3.325 General exclusions—first-year qualifying expenditure

A4.204 Claims procedure—corporation tax

B4.130 Summary of OECD guidelines on arm's length principle

C3.1814A CGT exempt assets—qualifying corporate bonds (QCB)

C2.501A Compensation and capital gains tax—overview

A1.810 Limitation

E5.406 Employees of European Union delegations—tax exemptions

C2.201 Allowable expenditure for capital gains—overview

B2.315 The concept of wholly and exclusively

C2.108 Contingent liabilities

E4.1146 The PAYE cumulative basis—overview

E1.1435 Appealing transactions in securities counteraction notices

C2.1168 Property rich collective investment vehicles—ceasing to meet the exemption election requirements

D1.404B Large company definition for R&D tax relief

E4.1167 Payments made after leaving and after issue of form P45

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

B5.846 Charities and close companies

D4.104 Company residence and the case law test

E1.416 Dividends from non-UK resident companies—general

I5.1304 Beneficiary with contingent interest