Example 1—simple apportionment to trustees
The A Trust holds 25% of the issued share capital of company X Ltd, and 5% of the issued share capital of company Y Ltd.
On 1 January 2000, X Ltd sells to Y Ltd an asset worth £250,000 for £100,000 (an undervalue of £150,000).
M has an interest in possession which commenced before 22 March 2006 in one third of the A Trust, and the remaining two thirds are held on discretionary trusts.
The value transferred by X Ltd is apportioned
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