Section 202 | Close companies.

(1)The persons liable for tax chargeable by virtue of section 94(1) or section 99(2) above are—

(a)the company making the transfer of value concerned, and

(b)so far as the tax remains unpaid after it ought to have been paid, the persons to whom any amounts have been apportioned under section 94 above and any individual (whether such a person or not) the value of whose estate is increased by the company’s transfer.

(2)A person to whom not more than 5 per cent of the value transferred by the company’s transfer is apportioned shall not as such be liable for any of the tax; and each of the other persons to whom any part of that value has been apportioned shall be so liable only for such part of the tax as corresponds to that part of that value.

(3)A person the value of whose estate is increased by the company’s transfer shall not as such be liable for a greater amount than the amount of the increase.

(4)No person other than those liable under this section shall be liable for any tax chargeable by virtue of section 94(1) or section 99(2) above.