I would like to know how best to structure a group of companies, such that a development company can pass assets straight to a holding company, without incurring tax liabilities.
Arthur Weller replies:
In a group situation, in which a holding co-owns 75+% of the shares in one or more subsidiary companies, assets can be transferred from one group co to another group company on a no gain/no loss basis for capital gains tax purposes. The same applies to stamp duty land tax (SDLT), i.e., no SDLT on intra group transfers.