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Hi Alan, Section 597AA excludes disposals of shares to ANOTHER COMPANY where the individual remains connected with the company following the disposal. My client sold shares in his company to his brother and therefore appears to not be excluded by this. However, Revenue guidance 19-06-02b 3 (vi) says the relief does not apply to "shares or securities where the individual remains connected with the company following the disposal". - but does not specify this is for a disposal to a company only. Does this catch my client even though the legislation specifies the restriction applies to disposals to a company only? Thanks, David

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Asked on 16 September 2019 4:27 pm
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