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Asset realisation

Mixed shareholdings - solution for all?

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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

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By Accountant A
12th Feb 2020 17:09

Deleted ....

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Psycho
By Wilson Philips
12th Feb 2020 22:13

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.

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By Coops
14th Feb 2020 08:50

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.

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Replying to Coops:
Psycho
By Wilson Philips
14th Feb 2020 13:52

I think that is the answer that kicks the OP’s idea into touch!

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