Can someone help please?
If a company wishes to become an LLP, but doesn't qualify for disk corporation relief because the assets are over £100k, what would be the most tax efficient way of doing this?
The balance sheet of the company contains goodwill purchased from a partnership on incorporation, but this is now worth much more, so this is the main sticking point.
I presume any gain made by the shareholders could be rolled over into their share of the LLP, assuming everything is transferred?
I'm thinking that the only impact would be that CT would be due on any increase in the value of goodwill, as this would need to be sold at MV due to the parties being connected.
Am I missing anything else? And is there any way to avoid/defer the CT on the goodwill "gain"?
Thanks in advance for your help