A company whose sole activity is the ownership of a residential investment property is owned by parents & 1 son (over 18).
The family want to give shares to another son (also over 18).
If the parents gift the shares then it won’t qualify for gift relief (as the company is not trading).
If the company issues new shares at par then presumably this will be caught under the value shifting anti-avoidance & hence be treated as a part disposal – is that correct?
Presumably the number of shares gifted/issued could be set to use the fathers annual exemption?