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Is a transfer of company shares to a director treated as taxable income?

Question:

If investments (i.e., shares) owned by a limited company are transferred to a director, with no payment physically changing hands, I assume this would be regarded as income in the hands of the director and be subject to income tax? I'm comfortable with it being deemed to be a sale at market value for the purposes of corporation tax on any gain on disposal for the limited company and potential capital gains tax for the director further down the line, if and when the shares get sold. But the transfer of the investments themselves is just income, as though the company had paid the director that same value as salary, I assume. 

Arthur replies: 

In HMRC’s Employment Income Manual at EIM21647, you can see that in your scenario, where an employer transfers assets to an employee by virtue of the employment, this is taxable income based on the present market value of the assets, and is subject to income tax, as you have written. 

If investments (i.e., shares) owned by a limited company are transferred to a director, with no payment physically changing hands, I assume this would be regarded as income in the hands of the director and be&nbsp

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This question was first printed in Business Tax Insider in April 2026.