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C5. Gift to a company

INHERITANCE TAX

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Gift with reservation of benefit 

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- Query whether transfer to company owned by transferor can be a gift

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- If the transferor owns all the shares in the company there will usually not be a transfer of value, but query whether it can amount to a gift?

Legislation: 

Cases: 

HMRC manuals: 

Commentary: McCutcheon 7-51; 

See also:

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 © 2023 by Michael Firth, Gray's Inn Tax Chambers

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