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HMRC internal manual

Capital Gains Manual

Connected persons: directors of a company

Directors of a company are not necessarily connected persons in relation to transactions between themselves. Whether or not one of them controls the company or two or more together control the company, they are not connected persons unless they are ‘relatives’, see CG14580, or partners, see CG14610. TCGA92/S286 (7) makes two or more directors connected persons only in relation to transactions with the company.