Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Readers’ forum: Would transaction be taxed as income?

08 April 2024
Issue: 4931 / Categories: Forum & Feedback , Income Tax
Transactions in securities

Our client has the following structure in place. The trading subsidiary (Tradeco) is owned 100% by a holding company (Holdco) which in turn is owned by 11 shareholders. These are four individuals and seven companies as follows – A B C D A Ltd (owned 100% by A) B Ltd (owned 100% by B) C Ltd (owned 100% by C) D Ltd (owned 100% by D) E Ltd F Ltd and G Ltd. These are all close companies and no single shareholder (or combined with their companies) owns more than 25% of Holdco.

There is a shareholders’ agreement (SA) in place which values the company at £5m (regardless of reserves in either Tradeco or Holdco). The reserves currently in the company (Holdco + Tradeco) are c£2m.

Person A (PA) is looking to retire immediately and wants to sell his...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon