This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

How should I structure a group of companies without incurring tax liabilities?

Question:

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. 

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: <

...


This question was first printed in Business Tax Insider in October 2021.