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HMRC internal manual

Inheritance Tax Manual

Employee benefit trusts: dispositions by close companies: procedure where exemption is restricted

Where IHTA84/S13(2) stops S13(1) from applying, the disposition by the close company to the employee benefit trust is a transfer of value (IHTM04068) unless IHTA84/S10 (IHTM42957) or IHTA84/S12 (IHTM42958) apply.

Where there is a transfer of value you will need to consider whether or not business relief applies (IHTM42965).