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<h1>Liquidation distributions are taxed as shareholders' capital gains; company distributions not treated as transfers under transfer provision</h1> When a company distributes assets to its shareholders on liquidation, that distribution is not treated as a transfer by the company for the relevant transfer provision. A shareholder receiving money or assets on liquidation is taxable under capital gains: tax applies to the amount received or the market value of distributed assets on the distribution date, reduced by any amount previously assessed as dividend. That net amount is treated as the full value of consideration for computing capital gains under the applicable provisions.