Section 100 — Inheritance Tax Act 1984: Alterations of capital, etc. where participators are trustees.

Alterations of capital, etc. where participators are trustees. 100 1 This section applies where, by virtue of section 98 above, an alteration in a close company’s share or loan capital or of any rights attaching to shares in or debentures of a close company is treated as a disposition made by the participators, and—

a a person is a participator in his capacity as trustee of a settlement, and b the disposition would, if the trustee were beneficially entitled to the settled property, be a transfer of value made by him, and c at the time of the alteration an individual is beneficially entitled to an interest in possession in the whole or part of so much of the settled property as consists of unquoted shares in or unquoted securities of the close company . 1A Where the interest in possession is one to which the individual became beneficially entitled on or after 22nd March 2006, this section applies only if the interest in possession is—

a an immediate post-death interest, b a disabled person's interest, or c a transitional serial interest, or falls within section 5(1B) above.

2 Where this section applies, such part of the individual’s interest shall be treated for the purposes of Chapter II of Part III of this Act as having come to an end at the time of the alteration as corresponds to the relevant decrease of the value of the property in which the interest subsists, that is to say the decrease caused by the alteration.