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Transaction in securities - what do we think?

staged transfer of shares

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company is owned 70% by Mr A, 15% Mr B and 15% Mr C.

Plan is that Mr A will retire over next 5 years and B will acquire his shares for £500k.  

Plan was that B will set up holding company and receive cash from target company by way of loans / dividends over next 5 year to repay A for his shares, say at 15% or so per year.

Issue is that TIS s685 could be in point as amount transferred is less than 75%.

any comments ?

in your experience - would HMRC grant clearance? 

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By chicken farmer
31st Jan 2020 12:18

There isn't enough information here to give any meaningful opinion. "Further and better particulars required".

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By Montrose
02nd Feb 2020 22:28

Who benefits from taking a risk by not seeking clearance?

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By Tax Dragon
03rd Feb 2020 06:18

I'm assuming from your not providing further and better particulars that you no longer require comment.

I would anyway suggest that Mr A should take advice before agreeing to such a plan. (What's the point of the plan anyway? Seems to leave everyone potentially worse off.)

Which of the parties are you advising?

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