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?