The directors of a company with substantial property interests wish to protect those interests from trading risks.
We advise the directors to effect a restructuring of the business. We create a group structure and transfer the property into the new holding company. We are able to do this without incurring any Stamp Duty Land Tax liability nor any charge to Capital Gains Tax and without incurring Stamp Duty on the shares transferred. The new structure protects the property interests from the risks of the trading company whilst reserving for the shareholders in the holding company relief from inheritance tax on the value of their shareholdings.