partner is a participator or a company which is a 51% subsidiary of such a close company, in any circumstances whatsoever, or (b) a person within sub-paragraph (i), (ii) or (iii) of paragraph (a) enjoys a benefit deriving (directly or indirectly) from the property or any derived property. (3) A ???relevant reduction??? in the value of the individual???s estate occurs??? (a) if and when the value