Client has set up two companies with one share in each held by himself.
He now wants one company to be the holding company and to purchase his share in the other. I cannot see that clearance is needed from HMRC as neither company has traded and therefore has any value yet. A second opinion would be appreciated.
Further trading companies may be purchased in teh future but these will be purchased by the holding company to form a group.
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I agree. There is nothing client needs clearance for. He does not need CGT exemption for share for share exchanges, as the gains he will realise will be £Nil in any event.