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Family Succession Planning

Would TiS clearance be given in a 70:30 husband:wife company where wife retires but husband stays on

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Our client is a family owned (by a couple in their sixties) company trading in the hospitality industry.  It is owned 70:30 in the husband's favour.  The wife wishes to now retire and realise the capital value of her shares.  The couple's daughter works in the business and now has the experience and expertise to take over her mother's role.  It is proposed a new holding company will be formed with 30 subscriber shares held by the daughter.  H & W will sell their shares to Holdco with H taking shares and W taking debt, to be paid down over a number of years by dividends up to Holdco and paid out against the debt.  Does the fact that H still has a controlling holding mean TiS clearance will be refused?  Any comments gratefully received?

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By Tax Dragon
02nd Sep 2021 16:43

Can't see clearance being granted myself, but SIAS. Don't ask don't get. (Etc.)

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