Close companies
Administration
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
Exemption
Generally
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
Generally
Material interest, meaning
Capital gains tax relief on later gifts of shares
Capital, alteration of
Generally
Potentially exempt transfer
Trustee participators
Chargeable gains
Former apportionments
Generally
Transfer of assets at undervalue
Clearances
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
Generally
Return payment to company, relief for
Control of, meaning
Control, meaning
Generally
Rights to be attributed
Rights to be attributed etc.
Controlling persons
Associate
Associated company
Director
Loan creditor
Participator
Crown, controlled by or on behalf of
Death (transfers at)
Defined
Director, meaning
Disguised remuneration
Dispositions for benefit of employees
Disregarded preference shares
Distributable income apportioned among participators
Annual payments to charity
Generally
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
Generally
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
Exclusions
Fall-in-value relief
Foreign branch exemption regime
Foreign companies (transfers by)
Foreign permanent establishment
Gateway
Generally
Gifts with reservation (rules not applied)
Group relief
Group transfers
Impact on form of trust
Income tax charge, release of loan to participators
Death
Generally
Income charged
Income tax treated as paid
Information, power to obtain
Person liable
Released or written off
Settlors
Trustees
Industrial and provident societies, not close companies
Information
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
Generally
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
Generally
Participators
Interpretation of statutes
Investment in/loan to buy interest in, interest relief
Investment-holding
Liability for tax
Extent of
Less than five per cent transferred
Persons liable
Lifetime transfers
Chargeable lifetime transfers
Exemptions
IHT rate
Value of transfer
Liquidation
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
Charge
Consequences for participator
Default interest
Exemptions from charge
Generally
Loan or advance, meaning
Money lending business
Notification to Revenue
Possible changes to the rules
Release
Released/written off
Relief on repayment etc.
Reporting requirements
Revenue's entitlement to make assessment
Self-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
Exceptions
Generally
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
Meaning
Assets-based test
Controlled by five or less participators
Controlled by participators who are directors
Generally
Misappropriation of funds by director
Non-close companies, involvement with
Non-resident companies, not close companies
Non-resident trusts
Other close companies (transfers to)
Overview
Participator, meaning
Participators
Apportioned tax charged on
As beneficiaries
Cumulation
Definition
Interest in more than one company
Interest in possession
Liability for tax
Minority
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
Winding-up, business property relief