Revenue Note for Guidance
This section provides that a liquidator of a company is to be treated for capital gains tax purposes as the nominee of the company. Transactions in the assets by the liquidator are to be treated as transactions by the company so that any chargeable gains or allowable losses are deemed to be gains or losses of the company. The transfer of the assets from the company to the liquidator on vesting is not regarded as a disposal from one to the other. The words “or otherwise” are used in the section to cover, for example, the case where on a voluntary liquidation the liquidator might apply to the court for a formal vesting of assets of the company by virtue of section 614 of the Companies Act 2014.
Relevant Date: Finance Act 2019