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Home / Simons-Taxes /IHT, trusts and estates /Part I6 Close companies and partnerships /Division I6.1 Close companies /Transfers of value by close companies / I6.121 Introduction to transfers by close companies
Commentary

I6.121 Introduction to transfers by close companies

IHT, trusts and estates

I6.121 Introduction to transfers by close companies

IHTA 1984, s 94 deals with the situation where an individual (or a group of individuals) exercises control over a close company and uses it to pass value to an intended beneficiary. This is a transaction which, but for IHTA 1984, s 94, could not give rise to a chargeable transfer for IHT purposes (although a charge to CGT might

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