Readers’ forum: Exception for family or personal relationships

Our client (A) is 66 and owns 80% of an engineering company which he set-up 30 years ago. The other 20% is owned by a long-term employee (B) in his 40s who joined 15 years ago. After working his way up he is now the managing director responsible for running the company.

A’s involvement in the business has progressively reduced. He wants to retire and pass his 80% shareholding to B.

A is comfortably wealthy and has no children to leave his estate to. He wants to gift his 80% shareholding to B so that the company can continue in its existing form – there is no desire to sell the company and transferring to general employee ownership would not be appropriate.

The income tax on the receipt of these shares (valued at £1.5m) would be unacceptable however it seems to us the gift would not...