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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Gifts to employee trusts: close companies: effect on shareholders

TCGA92/S239 (3), TCGA92/S125

See CG57125 for the effect of TCGA92/S239(3) on the apportionment under TCGA92/S125 of if there is a gift or transfer at undervalue by a close company to an employee trust.