»Ê¹ÚÌåÓýapp

TCGA92/S8 (6)

»Ê¹ÚÌåÓýapp appointment of a liquidator in the case of a voluntary or compulsory liquidation of a company does not give rise to a disposal of

• assets by the company
• shares by the shareholders.

»Ê¹ÚÌåÓýapp reasons for this are

• the liquidator is treated for all Capital Gains Tax purposes as a `bare trustee', see CG34300+
• disposals by the shareholders take place when the liquidator makes distributions of assets, see CG40430+.

You should treat a receiver or manager who is appointed to control the affairs of a company in the same way as a liquidator even though that person may be a receiver for creditors or debenture holders. See CG15260 in connection with the allowance of expenses incurred by the liquidator in disposing of a company's assets.