Where a business operated by the husband has been transferred to a limited company and shares are allotted directly to husband and wife does this constitute a settlement and if so why is it not covered by the exemption in section 660A(6) Taxes Act 1988?
If the shares are allotted to a girlfriend who later becomes his wife does this constitute a settlement and does the exclusion in section 660A(3)(a) Taxes Act 1988 apply at all times or only up to the date of marriage?
As regards goodwill in the case of a trader offering personal services the goodwill is personal to him and it is difficult to see how this could be transferred to a company. If the director resigns and transfers his shares the company will not have the benefit of his personal goodwill ...
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