Close companies: apportionment: trusts and personal representatives
ESC/D12By concession (ESC/D12) relief under Section 124 may be given to trustees or personal representatives on the disposal by them of the shares in respect of which an apportionment has been made if
- income has been apportioned to either a beneficiary of the trust of a residuary beneficiary of the estate, and
- the tax on that income has been borne by the beneficiary, and
- the disposal (for Capital Gains Tax purposes) of the shares in question is by the trustees of the settlement or the personal representatives.