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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Employee benefit trusts: dispositions by close companies: liaison with CGT

If the transfer falls within IHTA84/S28, it will also be treated as a disposal at no gain or loss for CGT purposes under TCGA92/S239. You may receive an enquiry from CGT caseworkers asking us to confirm that a transfer of shares to the trustees of an employee benefit trust meets the conditions of IHTA84/S13 and should liaise with them as appropriate.