IHTM14853 | Lifetime transfers: transfers by close companies: exemptions
From HM Revenue & Customs · Inheritance Tax Manual
Any transfer by a close company is a deemed transfer () for Inheritance Tax purposes and is not a potentially exempt transfer (), but
the annual exemption () is available as the restriction in to deemed transfers of value does not extend to transfers under IHTA84/S95(5).
as is
spouse or civil partner exemption () to the extent that the estate of the spouse or civil partner of a participator is increased.
The exemptions for
small gifts (),
normal expenditure out of income (), and
gifts in consideration of marriage or civil partnership ()
are not available since they cannot apply to deemed transfers.