Four buy four

Partnership professionals A B C and D have traded together for many years but for commercial reasons each wishes to have their personal interest in the business transferred to A Limited B Limited C Limited and D Limited from 6 April 2011 onwards.

The partnership contains a separable activity which is being run by C. If a genuine split in the business occurred at 5 April 2012 with A Limited B Limited and D Limited continuing but C Limited commencing a fresh company can readers answer the following points?

First will this be a VAT transfer of a going concern (TOGC) at the later date only?

Second individual capital gains tax disposals occur at 6 April 2011 (where entrepreneurs’ relief can apply) but what are the capital gains tax...