Related Commentary  Related CasesRelated HMRC Manuals

167(1)  Subject to section 167A, section 165(4) shall not apply where the transferee is a company which is within subsection (2) below.

167(2)  A company is within this subsection if it is controlled by a person who, or by persons each of whom–

(a)is not resident in the United Kingdom, and

(b)is or is connected with the person making the disposal.

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