I3.366 Fall In Value Relief—Close Companies

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Commentary

IHT, trusts and estates

There is provision¹ for cases where the property transferred by the lifetime transfer (see I3.361) consists of shares or securities² in a close company and at any time after the transfer and before the relevant date there is a relevant transaction in relation to the shares. For this purpose 'relevant transaction' means³ a transaction which is:

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•�� a transfer of value made by the company, or
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•�� an alteration in unquoted share or loan capital of the company or an alteration in any rights attaching to unquoted shares in or debentures of the company. Unquoted shares or debentures

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