Hope all is well. I am looking into ways to do this! There are 4 companies within a group with a single Shareholder/director as below
Company A - Mr X Shareholder (100%) formed in Jan-21 - £1-1 share
Company B - Mr X Shareholder (100%) formed in Jan-21- £1-1 share
Company C - Mr X Shareholder (100%) formed in Jan-21- £1-1 share
Company D - Mr X Shareholder (100%) formed in Jan-21- £1-1 share
Ideally, Company D will replace as RLE in Co, A,B & C (Parent/Subsidiary set up) and Mr X will remain as the 100% shareholder in Co D. The issue is, Company A, has generated about £40k per month from Management services this year post incoporation, where as Co B and C are still dormant, so share transfers can be done @ £1each. Also Co A has obtained a bank loan for its actual trade to be paid into next year, so what are the implication if we change the structure now?
Question is does it require a valuation of Co A at this point for Co D to be the RLE or can it be back dated effective Jan-21 without trigerring any Tax implication? What I'm thinking is, to value Company A at present, then do a share transfer to Co D which will trigger Capital gains for Mr X and Stamp duty for Company D or we can simply back date this on Companies house now to Jan-21 and Remove Mr X from Co A, B and C and attach Co D to these companies to make Co D Parent?
Not sure if I have explained correctly, but If someone can clarify will be greatful.