Readers’ forum: Would sale of shares attract relief?

Until February 2021 K Ltd a trading company was owned by four unconnected individuals A B C and D. C and D wanted to exit and so a holding company was set up owned by A and B. This acquired the shares in K Ltd held by C and D (amounting to 49% in total). The other 51% of the shares in K Ltd continued to be held by A and B. There were also a small number of non-voting shares in K held by the spouses of A and B.

To simplify the structure before a potential sale in 3-4 years the non-voting shares were bought back by the company at par and a share-for-share exchange was carried out in June 2022 under which A and B exchanged their shares in K Ltd for new shares in H Ltd. Clearance was obtained. H is thus...