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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Close companies: transfers at undervalue: employee trusts

If the asset is transferred to an employee trust TCGA92/S239 (3) modifies the restriction in TCGA92/S125. The figure to be apportioned amongst the shareholders is the lower of the difference between the consideration paid by the trust and

  • the company’s allowable acquisition costs or
  • the market value of the asset.See CG36000+ for further instructions on employee trusts.