I own 100% of a company formed as a special purpose vehicle (SPV) to hold ownership and rent three properties. When my wife and I no longer need the income from this, I wish to pass control and benefits to my children. Can this be done tax-efficiently and benefit from capital gains tax (CGT) holdover relief by forming a trust for it (even though the company currently owns the property)? 

Arthur Weller replies:  

You could: (a) gift the shares in the company to your children now. However, if this will trigger significant capital gains tax (CGT), you would obviously think twice. You could (b) wait until you die and leave the shares to your children in your will. This will 'wash out' the capital gain but most likely impact on your inheritance tax (IHT) position. Or you could (c) gift the shares into a trust, using gift holdover relief, and then after a suitable period of time, the trust could appoint out the shares to your children, once again using gift holdover relief. This last idea probably needs professional advice. It also depends on the value of the shares and the availability of your IHT nil rate bands. It would perhaps help to share ownership of the shares with your wife.