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DP = AP NGNL, If <75%, :red_cross:ctrl co, Definition of ctrl co (must…

- - - - NGNL
    - - AP
        Transferor's AP
        (+)Transferor's PE
- - - - Beneficiary
        
        disposed of
        
        Taxable on beneficiary
        
        AP: MV at date of trsf ownership
        
        AD: date of trsf ownership
      - Executor / trustee
        
        disposed of
        
        Taxable on executor
        
        AP: MV at date of death
        
        AD: date of death
      - Legatee recv real property in lieu of cash
        
        disposed of
        
        Taxable on legatee
        
        AP, lower of:
        
        MV at date of trsf
        
        legacy money
        
        AD: date of trsf ownership
  - - - Chargeable asset
        
        owned by indv. his wife / jointly / connected person, citizen
        
        trsf to ctrl co
        
        consd substantially in shares (at least 75%) & bal in money payment
      - Tax implication
        
        Transferor
        
        Disposal of shares
        
        subj to RPGT
        
        AP
        CP
        (+)PE
        (-)cash payment
        
        NGNL
        
        Transferee
        
        Actual acq ignored
        
        AP
        CP
        (+)PE
        
        AD: date of trsf
- - - - AP
        Transferor's CP
        (+) Transferor's PE (EC+DT)
- - - - AP
        Transferor's CP
        (+) Transferor's PE (EC+DT)
      - AD = date of asset trsf