The Inheritance Tax Act 1984 contains two separate sets of charging provisions:

Occasion (1): Transfer of value by the company

Where a close company makes a transfer of value (as defined in IHTA 1984, s. 3(1)), tax is charged under IHTA 1984, s. 94 as if each individual to whom an amount is apportioned had made a transfer of value of such amount as after deduction of tax (if any) would be equal to the amount so apportioned, less the amount (if any) by which the value of his estate is more than it would be but for the company's transfer. For this purpose his estate shall be treated as not including any rights or interests in the company (the significance of this proviso is explained below).

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