The principle upon which the taxable amount transferred by close companies (IHTM14851) is established is that where an amount is transferred by a close company and ends up wholly or in part still in the beneficial ownership of the individual participator, or still held within the settled fund, there is no claim on the property or part because the value/property remains in the same hands. The taxable amount is represented by what does not remain in the beneficial ownership of the individual, or in settled property cases, what does not remain within the settled fund. There is an example of this at IHTM16247. .

This result has some kinship with IHTA84/S53 (2).

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