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In a simple Share for Share arrangment whereby 100% of the issued share capital of a Tradeco held by one individual were to be transferred to a non UK company (Jersey/Isle of Man) in exchange for the same no. of shares in holdco, is there any CGT issues with the purchaser being a non UK company? 

Is there anything else I am missing here?

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By Wilson Philips
19th Oct 2021 08:52

The obvious question is “why?”

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By Justin Bryant
19th Oct 2021 10:57

Never mind CGT. This is more or less what the Fishers did (albeit with a business transferred to a Gibco), and assuming you get CGT/TiS clearance will likely result in ToAA issues (despite any such clearance) unless there are very good non-tax commercial reasons for it so that MD applies re any dividends etc.

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