Avoiding raising gains on a 1 man group restructure
Hello all
I have a client who owns 100% of two companies. We are looking to transfer his holding in one company to the other, thus forming a group structure. As he is disposing of shares in a business which has a Net Assets value of £90k, I assume there is a triggered gain. But is there any holdover relief available, as he still owns 100% of both companies, just now in a group structure.
Assuming there is not, does the position change if instead of a transfer, we do a share for share swap? I.e. Company A (net asset value of £100k) gives the shareholder another share in them, for his share in company B. I have seen this work in other set-ups, but have not tried this in a set-up where he already owns 100% of Company A. Surely share 2 of 2 is next to worthless to him?
Once the group is in place, we will then enact intra-group asset transfers, but leave the subsidiary as a dormant company.
Many thanks in advance for any help. Would really appreciate if you can link relvant Acts/schedules etc.
- RTI Fees 293
- Where's our 10%? 268
- Driving sales growth 213
- CIS late registration 208
- Cost of converting property - who pays? 204
- EIS 202
- Accounting for gift vouchers - paid for and donated 192
- Break up basis accounting 187
- Accounts production software for business SSC 186
- Best structure 184
- High Income Child Benefit Tax Charge Error? 176
- iQor recovering HMRC debts again 153
- Is commission on sales always vatable? 137
- Integrate accounts software with infusionsoft 135
- SEIS and DeMinimus Aid 133
- Property does not qualify for FHL, what is allowable? 119
- Employers NIC holiday paper application form 114
- Child benefit 111
- National Insurance when leaving UK 106
- Trusts - loan to beneficiary 106
