Consider a scenario where a shareholder is facing a gain at 28%.
This would be the case when he is disposing of a company which does not qualify for Entrepreneurs’ Relief or if he has (or will) exceed the £10M lifetime Entrepreneurs’ Relief allowance.
Detailed advice should be obtained prior to any planning of this kind. For example a holding company will usually be inserted using a share for share exchange and we would not want this to trigger a tax charge. For bona fide commercial transactions this would not usually be the case and clearance could be obtained from HMRC.
This kind of structuring generally only results in a tax deferral, although in some cases the shareholder may go non-resident and depending on the jurisdiction they move to they could make a real tax saving.
You can use this form to request us to give you a call or if you prefer just leave us a message. Please be sure to leave us a contact number or email address for you and we will get back to you as soon as we can.