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Readers' forum: Keep trucking

06 August 2019
Issue: 4707 / Categories: Forum & Feedback
Filing obligations following a group restructuring

I have a client who operates in the road haulage sector. The business is highly competitive and the client is wary that his customers and competitors might find out how much profit the company is making.

A restructuring has occurred with a new offshore holding company now in place with two trading subsidiaries. The intention is to move central management costs into Holdco and to acquire a fleet of new vehicles into Holdco which will then be leased to the two trading companies at a profit. This will reduce the subsidiary company profits and increase the Holdco profits by the same amount.

Holdco is registered for UK corporation tax so there is no loss to HMRC. Importantly however Holdco has no accounts filing obligations offshore so customers and competitors cannot work out the true group profit.

Can readers spot any flaws in this strategy where for instance deductions...

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