We currently have a client with the following share structure:
A Voting shares
Dad 50
Son 50
B Non-voting shares
Son 100
The non-voting shares have been issue for several years and are effectively used to pay the son a "salary".
Now the family plan to:
Dad to sell 25 voting shares to son for market value. Thereafter it will be 25 Dad/75 Son.
However, in order to maintain their dividend income requirements it is proposed to issue some C Non-voting shares to Dad.
Do you think this will be caught by the new anti-avoidance rules in FA (no 2) 2005 re employment related securities?
Regards
tv
tv