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.