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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Assets held on 6/4/65: transferred to close companies

TCGA92/SCH2/PARA21TCGA92/SCH2/PARA21 provides that, to the extent that the gain on a disposal of shares of a close company reflects an appreciation in value of an asset transferred to the company by a person who controls the company (or a person connected with him or her), the gain shall be deemed, for the purposes of the time-apportionment rule, to have begun to grow at the date when the asset was transferred. This is an anti-avoidance provision.