Readers' forum: Transfer window

My client is a charitable trust that owns and rents out a sports pavilion. It has opted to tax it and is registered for VAT. The trust is to be turned into a charitable incorporated organisation (CIO) which will take over the lease of the property and enter into a redevelopment project. The CIO has been created and legal discussions are continuing on the building contracts. The business of the trust needs to be transferred to the CIO which must register for VAT.

The most obvious way to do this is by way of a transfer of going concern with the CIO taking over the existing registration number. I am not sure how that would work in practice given that we do not know when the negotiations will be completed or whether there might be a hitch that would cause a significant delay. I do...