Close companies: apportionment: trusts and personal representatives
Where shares are held by
- trustees of a settlement or
- personal representatives of a deceased personincome may be apportioned to one or more beneficiaries of the trust or estate. If the shares are subsequently disposed of by the trustees or personal representatives, strictly TCGA92/S124 cannot apply, because it only applies where the disposal of the shares is by the person who was assessed to Income Tax.