3rd Party Sale Post Incorporation

A partnership incorporated about a year ago and sold goodwill to the new company creating sizeable directors loan accounts.

We have started amortising the goodwill, but no corporation tax relief has been claimed.

The directors are now looking to sell the business to an unconnected 3rd party at arms length.

Is a sale of shares just never going to happen in this scenario (favouring purchase of goodwill and assets)? If someone purchased the shares presumably this would not change the nature of the goodwill in the accounts and no ct relief would still apply and what would happen to the directors loans? Can these be cancelled in some way?

Thanks.