Alterations of share capital

Annual exemption

Anti-avoidance provisions

Application (Chap. 2)

Application of IHT rules

Apportionment of income, disposal of shares

Arrangements conferring benefit on a participator

Assets held on 6 April 1965

Associate, meaning

Associated company, meaning

Attribution of gains to participators

Basis of winding up under s. 439(3)

Beneficial loan treatment (exemptions)

Benefits for participators

Charge to tax



Measure of the benefit

Relief for a return payment

Tax avoidance arrangements conferring benefits

Building societies, not close companies

Buying an interest in, loan interest relief

Associate, meaning

Eligibility requirements


Material interest, meaning

Capital gains tax relief on later gifts of shares

Capital, alteration of


Potentially exempt transfer

Trustee participators

Chargeable gains

Former apportionments


Transfer of assets at undervalue


Close company, meaning

Companies which are not close companies

Companies controlled by or on behalf of Crown

Companies involved with non-close companies

Meaning of 'shares beneficially held by the public' etc.: s. 446

Particular types of company

Particular types of quoted company

Registered pension schemes: s. 444

Compensation for reduction in value of land

Concept of control

Conferring benefit on participator, charge to corporation tax


Return payment to company, relief for

Control of, meaning

Control, meaning


Rights to be attributed

Rights to be attributed etc.

Controlling persons


Associated company


Loan creditor


Crown, controlled by or on behalf of

Death (transfers at)


Director, meaning

Disguised remuneration

Dispositions for benefit of employees

Disregarded preference shares

Distributable income apportioned among participators

Annual payments to charity


Transfer of shares and purchase of assets

Distributions, beneficiary of

Distributions, expenses incurred in provision of benefits treated as

Additional persons treated as participators

Companies acting in concert or under arrangements

Employment income, exception for benefits treated as


Meaning of participator

Transfers between resident companies, exception for

Divorced couples

Employee trusts

Employees and employee benefit trusts

Exception to s. 554Z2(1)

Exceptions (not transfers of value)

Agricultural property

Employees (transfers to)

Interest-free loan

Non-UK domiciled participators (transfers to)

Ordinary course of business

Retirement benefits

Exceptions and exemptions


Fall-in-value relief

Foreign branch exemption regime

Foreign companies (transfers by)

Foreign permanent establishment



Gifts with reservation (rules not applied)

Group relief

Group transfers

Impact on form of trust

Income tax charge, release of loan to participators



Income charged

Income tax treated as paid

Information, power to obtain

Person liable

Released or written off



Industrial and provident societies, not close companies


Information, power to obtain

Inheritance tax

Alteration in share or loan capital

Annual exemption

Anti-avoidance provisions

Close company, meaning

Dispositions in trust for employees

Exceptions and exemptions


Inter-group disposals

Liability for tax

No apportionment made

Participator, meaning

Preference share values

Relief on sale of shares after death

Settled property where trustees are participators

Shares and securities, fall in value of property transferred

Surrender of losses or unrelieved advance corporation tax

Transfer of value

Transferee company, participator with interest in

Inheritance tax implications of funding an EOT

Business property relief

General rules

Relief for s. 86 employees' trust

Special relief in year of acquisition of controlling interest

Intangible fixed assets, participator test

Interest in possession in settled property attributed to participators

Interests in possession



Interpretation of statutes

Investment in/loan to buy interest in, interest relief


Liability for tax

Extent of

Less than five per cent transferred

Persons liable

Lifetime transfers

Chargeable lifetime transfers


IHT rate

Value of transfer


Listed companies, exclusion

Loan creditor

Loan creditor, meaning

Loan creditors (defined)

Loan relationships

Deeply discounted securities

Loans to participators

Loans to participators

Anti-avoidance provisions

Back-to-back arrangements


Consequences for participator

Default interest

Exemptions from charge


Loan or advance, meaning

Money lending business

Notification to Revenue

Possible changes to the rules


Released/written off

Relief on repayment etc.

Reporting requirements

Revenue's entitlement to make assessment


Service company incorporated to pay outgoings of estate agency business

Sum transferred to director's loan account

Loans to trustees

Loans/benefits to participators, corporation tax charge

Arrangements for paying tax on behalf of group members



Information, power to obtain

Release of loan to trustees of settlement which has ended, income deemed to arise to company

Repayment/release of loan

Treated as made by close company

Treated as made to participator


Assets-based test

Controlled by five or less participators

Controlled by participators who are directors


Misappropriation of funds by director

Non-close companies, involvement with

Non-resident companies, not close companies

Non-resident trusts

Other close companies (transfers to)


Participator, meaning


Apportioned tax charged on

As beneficiaries



Interest in more than one company

Interest in possession

Liability for tax


Term used in respect of non-close companies

Transfer within three years before death of

Trustee participators, transfer by

Participators (defined)

Preference shares

Proposal that company should be allowed to lend to EOT

Quoted companies not treated as

Registered pension schemes, shares held on trust for

Relief on sales of shares after death

Repayments and return payments, restriction of relief

Rights and interests

Share incentive plans

Shares and securities

Apportionment of income

Beneficially held by the public

Transfer of assets at an undervalue

Transfer of assets by investors

Tax planning

Transfer of assets at an undervalue

Transfer of value

Alteration of capital/rights of shares

Apportionment of tax

Excluded surrenders

Minority participators

Participator trustees

Participators in two companies

Preference shares disregarded

Transfers from at undervalue

Transfers within a group

Transfers within three years before death of participator

Treatment of some persons as participators or directors for purposes of s. 439(3)

Trustees as connected parties

Trustees, attribution of gains to

Winding up


Winding-up, business property relief