Question:
A UK limited company (A Ltd) is owned 100% by me, and I am also an employee and director. The company is a trading company. I've now decided to set up a holding company in the EU, which will own 100% of the shares in A Ltd. I will own 100% of the EU company. My question is: is there capital gains tax or stamp duty payable on the share transfer?
Arthur Weller replies:
The 'share for share exchange' rules should apply here and there should be no capital gains tax or stamp duty on the swapping of your shares in the original company in exchange for your shares in the new company. See www.hmrc.gov.uk/manuals/cgmanual/CG52521+.htm and www.hmrc.gov.uk/manuals/cgmanual/CG52800.htm.
