Group Tax Planning
A successful retail franchise in the motor trade is looking at opening a second outlet. No IPR's, no freehold property etc.......
From a tax perspective, would it be better to set up a group structure (Holding Co owns A Ltd and B Ltd) or for the current shareholder to own the shares in A Ltd and B Ltd directly.
Group structure presumably benefits from group loss relief (although 1st franchise break even in Year 1) but the sale of either A Ltd or B Ltd separately in due course would attract Entrepreneurs Relief.
Which course is best ? Comments appreciated.
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