Trading company client has reached end of its life, with several £m in cash (from realisation of trading stock, premises etc). One of the shareholders is a company (25%), the rest individuals. Plenty of reserves so could they buy back the corporate's shares (exempt dividend) and then liquidate? Thus saving tax on the corporate element
Thanks
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No scope for substantial shareholding relief re the corporate shareholder?
https://www.accaglobal.com/us/en/technical-activities/technical-resource...
https://www.pinsentmasons.com/out-law/guides/the-substantial-shareholdin...
CTA 2009 section 931B(d)?
And agree with above - why try to be clever if SSE applies?
But would SSE apply in this case? Not enough info to be certain, but on the face of it - no.
Also see s931RA CTA 2009, which says (broadly) that, for corporate sellers, there is no deduction of exempt distributions when calculating the capital gain arising on the disposal.
This follows the decision in the Strand Futures case.