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HMRC internal manual

Capital Gains Manual

Reliefs: employee-ownership trusts: defining significant and controlling interests: further definitions


In CG67875 ‘third party’ means a person other than,

  • C or a member of a group of which C is the principal company,
  • a person who is, or has at any time in the preceding 12 months been, a participator in C or in a member of such a group, or
  • a person connected with a person in the second point above.

In applying the guidance at CG67875, ‘close company’ and ‘participator’ have the same meaning as in IHTA84/S102.  The meaning of ‘participator’ is extended in the same way as in the second paragraph of CG67839.