Readers' forum : Winding down

My client is a sole practitioner accountant operating through a limited company. He owns 65% and 35% is owned by his wife who is employed by the company. The client owns the trading premises from which the company operates and has never charged rent to his company for its use. The premises are debt-free.

My client has a self-invested personal pension (SIPP). Having dealt with all the necessary formalities with regard to valuations and so on he wants to dispose of the trading premises to the SIPP. The SIPP will pay him the consideration. At the same time he intends to make a disposal of between 5% and 10% of his shares in his trading company to his adult son who is also a qualified accountant and who will eventually take over the business.

I think this transaction would enable him to qualify for entrepreneurs’ relief on the disposal...