In certain circumstances, a close company is treated as making a transfer of value (IHTA 1984, s. 94). Where this is so, the value transferred is apportioned between the participators according to their interest in the company. The tax payable by the company is the aggregate amount of the tax charged on each individual at the rate which would be charged if each individual had made a transfer of value of his apportioned share. See ¶603-700 and the Inheritance Tax Manual (IHTM16241ff).

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