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HMRC internal manual

Inheritance Tax Manual

Settled property: the charge when both a close company and interest in possession are involved

Where both a close company and an interest in possession (IIP) (IHTM16000) in settled property are involved the situations are catered for where

  • a close company makes a transfer of value and part of the value transferred would be apportioned to a trustee of a settlement, see IHTM04090
  • an alteration is made in a close company’s share or loan capital (or in any rights attaching to its shares or debentures), see IHTM04091
  • a close company is entitled to an IIP in settled property, see IHTM04092