Related Commentary  

136(1)  This section applies where the transferred property consists of shares in a close company and at any time after the chargeable transfer and before the relevant date there is a relevant transaction in relation to the shares; and for this purpose “relevant transaction”  means a transaction which is–

(a)the making of a transfer of value by the company, or

(b)an alteration in so much of the company’s share or loan capital as does not consist of quoted shares or an alteration in any rights attaching to unquoted shares in or unquoted debentures of the company,

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