For IHTA 1984, s 94 to apply, the close company in question must make a transfer of value1. Whether or not a disposition made by a close company constitutes a transfer of value must be determined according to the general rules of IHT (see Division I3.1).
Therefore, none of the following dispositions are normally chargeable dispositions under that section:
- Ìý
•ÌýÌýÌýÌý a disposition of excluded property2 (see I3.114).
- Ìý
However it should be noted that some excluded property categories relate only to property owned by individuals and therefore do not include property owned by companies – the provisions relating to foreign property owned by non long-term UK residents (for transfers on or
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Web page updated on 17 Mar 2025 17:19