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Tantalising transfers

19 October 2006
Issue: 4080 / Categories: Forum & Feedback

Our client owns 51% of a holding company whose major assets are three subsidiary trading companies that turn over in excess of £12 million p.a., generating profits of £1 million p.a. after remuneration and pension contributions. The value of the assets employed in the operating subsidiaries is £3.5 million. In addition to the trading subsidiaries, the company currently owns a small agricultural holding from which the agricultural activity is negligible and this is occupied by one of the directors.

Our client owns 51% of a holding company whose major assets are three subsidiary trading companies that turn over in excess of £12 million p.a. generating profits of £1 million p.a. after remuneration and pension contributions. The value of the assets employed in the operating subsidiaries is £3.5 million. In addition to the trading subsidiaries the company currently owns a small agricultural holding from which the agricultural activity is negligible and this is occupied by one of the directors.
The company is also in the process of purchasing from one of the directors a private residence with offices in the grounds which will be used by the company. The two properties referred to will each have a value of approximately £1.3 million.
We would appreciate readers' comments relating to the inheritance tax implications should our client die and the capital gains tax situation should he decide...

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