Chapter CG57828

Published date12 March 2016
Record NumberCG57828

Shareholders will often receive more than one capital distribution during the winding up of a company. Each distribution, other than the final one, is treated as a part disposal of shares so the residual value of the shares after each distribution is needed to attribute a proportion of the cost of the shares to the distribution (unless the distribution is “small”).

Where the shares of a company are unquoted at the date of the distribution and the liquidation is expected to be completed within two years of the distribution, HMRC will accept any reasonable valuation of...

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