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HMRC internal manual

Capital Gains Manual

Close companies: transfers at undervalue: transferee participator

ESC/51You should not apply TCGA92/S125 if the transferee is a participator or an associate of a participator in the company and

  • the transfer is treated as a distribution within ICTA88/S209 (2)(b) or (4), see CT1525 or
  • the transfer is treated as a capital distribution within TCGA92/S122, see CG57800+.