Transfer, not sale

I have just read the answers to No actual sale concerning the transfer of a freehold property from one company to another and the possible application of the substantial shareholdings exemption (SSE) when the company then leaves the group.

I agree with the comments of Tax Geek and when the new legislation in TCGA 1992 Sch 7AC was published I thought this or similar structures could be used to create a great way to ‘convert’ a capital gain on the sale of an investment property into a tax-free capital gain covered by the SSE.

However I think the reply should have gone on to say that if this was an innocent outcome then the tax analysis set out in the reply should be correct.

But if one tried to engineer the scenario then I think TCGA...