Transfer of Shares

Personal Shares transferred to holding company

Didn't find your answer?

Client has 50% ord shares in a Ltd Co. Other 50% are held by a holding company which he is not conncted to. Client has to declare same dividends as the holding company which isnt tax efficient for him. Client wants to transfer his 50% to his own holding company and then take dividends from the holding company, at a level and time that suits him.

What are the tax impications for him personally and the new holding company?

Will the shares he currently owns persoanlly need to be valued?

Many thanks in anticipation.

 

Steve

Replies (22)

Please login or register to join the discussion.

avatar
By paul.benny
22nd May 2024 09:56

@OP - if this is really a client, why would anyone give you advice here for free for which you will then charge your client?

And if that were to happen and the advice was bad, I don't think your PI insurer would be very sympathetic should client make a claim

Thanks (5)
Replying to Steveie1108:
avatar
By David Ex
22nd May 2024 10:35

Steveie1108 wrote:

I though my question was what this forum was for?
If it isn't, what is it for?

Well you’re wrong. You need to read the site owner’s conditions of use.

https://www.accountingweb.co.uk/any-answers/how-to-use-any-answers

“If you intend to plan a course of action based on what you read in here, you should instead be taking professional advice.”

“They are not here to provide free accounting advice.”

Thanks (3)
Replying to Steveie1108:
avatar
By Paul Crowley
22nd May 2024 11:38

Looks like you are on your own with this.
Cannot understand why.

Thanks (3)
Replying to Paul Crowley:
avatar
By Paul Crowley
22nd May 2024 16:23

Who did I reply to?
Something was there, surely?
I must be going senile

Thanks (0)
Replying to Paul Crowley:
avatar
By Leywood
22nd May 2024 17:15

Some of OP's vile comments have been removed. OP hasnt.
Moderation at its best, as per.

Thanks (2)
paddle steamer
By DJKL
22nd May 2024 10:05

Doable but paid for pros are required as you want to ensure nothing gets missed and all done in correct order, for that you need to pay.

Right now we have recently incorporated a partnership into Newco, swapped shares in Newco for shares in a holdco, hived up business and trade and in two weeks time we undertake a partition demerger of that company, despite to a degree understanding what we are doing no way would I run this, I am paying some pros a lot of money to plan, guide, execute, communicate with our solicitors and get things right- you likely ought to do similar . (My job today is get a "group" ERS scheme registered on our online portal for the pros to then make the required returns)

Thanks (0)
avatar
By nrw2
22nd May 2024 10:17

Considerations include:
- stamp duty reserve tax on transfer of shares to holdco
- personal CGT on transfer of shares to holdco
- potential share exchange in order to defer personal taxable gain of shares in 'Ltd Co' and roll base cost into holdco shares
- valuation of shares in 'Ltd Co' on transfer to holdco
- CT on eventual disposal of holdco's shares in 'LTD Co' (potential SSE)
- personal tax on extracting holdco's receipt of divs + gains from 'Ltd Co' (CGT, BADR, divs etc)

Thanks (1)
Replying to nrw2:
avatar
By Tax Dragon
22nd May 2024 10:20

A key word there being "include" - that's far from a complete list.

Thanks (3)
Replying to Tax Dragon:
avatar
By nrw2
22nd May 2024 11:31

Agreed, I used the word 'include' carefully!

Thanks (1)
Replying to nrw2:
avatar
By Steveie1108
22nd May 2024 10:50

Many thanks for your response - a sensible, helpful response at last. What a shame people feel the need to be sarcastic and pompous -Narcissistic people. Cant stand them.
thanks again.

Thanks (0)
Replying to Steveie1108:
avatar
By FactChecker
22nd May 2024 17:22

Shame I was out this morning and missed all the now deleted comments ...
... but "Narcissistic people. Cant stand them."?

How do you feel when catching sight of yourself in the mirror then? A bit queasy?

Thanks (2)
avatar
By Tax Dragon
22nd May 2024 10:18

Call me a wotsit full of my own arrogance if you like, but I agree 100% with paul.benny.

And if you cannot see the sense in what was said, you maybe should stand in front of a mirror next time you say "cocky idiot".

Thanks (9)
By Ruddles
22nd May 2024 10:24

How are you going to calculate the capital gain if you don't know the value of the shares?

Thanks (6)
avatar
By Steveie1108
22nd May 2024 10:36

Does everyone on here have a chip on their shoulder. Is it a pre-requisite that in order to answer any questions, you have to be sarcastic?
Forget I asked and get on with your day - sad people.

Thanks (0)
Replying to Steveie1108:
avatar
By Tax Dragon
22nd May 2024 10:46

What answers were you hoping for?

My quote for the work involved here is £5,250. Plus VAT. And I'm offering you mates rates there because you've taught me some new words. Lol.

(PS that doesn't include legals.)

Thanks (7)
Replying to Tax Dragon:
paddle steamer
By DJKL
22nd May 2024 10:49

Sounds cheap- for our exercise we are at the £100k-£120k mark(that does not include legals)

Thanks (0)
Replying to Steveie1108:
paddle steamer
By DJKL
22nd May 2024 11:02

Well, if you want to try the share exchange without any professional advice here is a link to a useful book.

https://www.amazon.co.uk/Taxation-Company-Reorganisations-Pete-Miller/dp...

No idea if most recent and whilst I have the book would never try exercise by myself, far too many snags for the unwary and things can get expensive if mistakes made.

Good luck, you will possibly need it.

Thanks (0)
Replying to Steveie1108:
By Ruddles
22nd May 2024 10:48

Another satisfied customer. Close the door on the way out.

Thanks (6)
Replying to Ruddles:
avatar
By Steveie1108
22nd May 2024 10:52

Like to meet up for a chat?

Thanks (0)
Replying to Steveie1108:
avatar
By David Ex
22nd May 2024 10:54

Steveie1108 wrote:

Forget I asked and get on with your day - sad people.

Nothing quite as sad as an abusive bully.

Thanks (5)
Replying to David Ex:
avatar
By Steveie1108
22nd May 2024 11:01

bully?

Thanks (0)
Replying to Steveie1108:
avatar
By FactChecker
22nd May 2024 17:27

What alternative post-hoc explanation would you now like to claim was the purpose of your "Like to meet up for a chat?" response to Ruddles?

Thanks (4)