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Home / Simons-Taxes /IHT, trusts and estates /Part I6 Close companies and partnerships /Division I6.1 Close companies /Close companies—the basics / I6.102 Definition of a close company for IHT purposes
Commentary

I6.102 Definition of a close company for IHT purposes

IHT, trusts and estates

A company is a close company for the purposes of IHTA 1984, ss 94–102 (Pt IV) if it is a close company for the purposes of the Corporation Tax Acts (as defined at D3.102), or would be such but for being resident outside the UK1.

Broadly, a company is close if:

  1. Ìý

    •ÌýÌýÌýÌý it is under the control of five or less participators (or any number of participators if those participators are directors), or

  2. Ìý

    •ÌýÌýÌýÌý more than half the assets of which would be distributed to five or less

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