This might be a specialist area of expertise, but I will give it a try.
Company A is a UK company which holds 100% shares in Company B which is a US Limited Liability Company. Company A is itself a 100% subsidiary of Company C, a French limited company. Company B has made losses historically and as of today has accumulated losses of approximately £1m. Company B owes around £1m to Company A in loans. It is now proposed that Company A sells the subsidiary Company B for a nominal amount to Company C (the ultimate holding company).
What is the most tax efficent way relieving accumulated trading losses in the foreign subsidiary, and how can the loss on loan be best relieved?