ÀÏ˾»úÎçÒ¹¸£Àû

Connected party disposals

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Connected party disposals

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

This note explains the general rules that apply in respect of the disposal of company assets to connected parties and highlights the issues that differ from a transaction between unconnected third parties. For an overview of corporate capital gains see the Corporate capital gains ― overview guidance note.

Generally, disposals between connected parties are deemed to take place at market value, regardless of any actual consideration paid or received. However, in certain circumstances which are discussed below, there may be an adjustment to the base cost of the shares.

See also Simon’s Taxes C2.109 onwards.

What are connected parties?

A company is connected with another company if:

  1. •

    the same person or group of persons control both companies

  2. •

    a person controls one company and persons connected with them control the other

  3. •

    a person controls one company and they, along with other persons connected with them, control the other

TCGA 1992, s 286(5)

A company is connected with another person if that person controls it alone or alongside persons connected with them.

Where two

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

Foreign exchange issues

Foreign exchange issuesOverview of foreign exchange provisionsForeign exchange (FX) movements are generally taxed following the rules applicable to the underlying income, expenditure, asset or liability on which they arise, broadly as follows:Capital assetsOn a realisation basis (ie on disposal)

14 Jul 2020 11:44 | Produced by Tolley Read more Read more

Loans written off

Loans written offCompanies sometimes provide directors, employees or shareholders with low interest or interest-free loans either as part of the reward package or on special occasions to help the individual meet significant expenditure. The employment income implications of these loans are discussed

14 Jul 2020 12:11 | Produced by Tolley Read more Read more

Maintenance payments

Maintenance paymentsMaintenance payments are payments made by a taxpayer to their former or separated spouse / civil partner for the maintenance of that person or their children. To obtain any tax relief for maintenance payments, one of the couple must have been born before 5 April 1935 and the

14 Jul 2020 12:12 | Produced by Tolley Read more Read more