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.