Ok thank you so given employer won’t sign this off because it’s a conflict and that transferring shares is not really a gift because client wants them back, if the transfer went ahead would it in fact be a straight capital gain requiring share valuation and deemed consideration? Client has no choice but to relinquish ownership if he is to retain job.

What’s has to happen is that client cannot be director or shareholder in company where there is a conflict and neither can wife.
Client wants to retain company hence no choice but to gift shares because client cannot own then the being that they are gifted back when conflict no longer exists.

Yes, resign as Director and gift shares. Appreciate the point and have also advised that this might be fine now!

Thanks for your response, he wants to retain company through his friend and take back ownership in a few years. Client is in forces and exits in a few years. Ownership is deemed conflict of interest in this case and also stipulates that wife ownership will also be deemed conflict. Idea is gift to sympathetic friend to remove ownership and conflict and get shared back in a few years.

Thanks for your response but I genuinely do have a client who is a NHS consultant who works privately and through a partnership. My concern is anti-avoidance legislation that effectively prevents this. Is this what you are referring to when you mention "beware of the tax consequences"?
Thank you for your help

just discovered they weren't actually married at that time, they married later in the year! Great!

£250,000!

I know but having just picked up the client and realising he is in trouble on this one I am trying to see what if anything can be done.

below market rate

yes, rental income reported