Alan Pink considers the tax implications when an owner-managed company transfers an asset to a director shareholder of the company.
Employment taxation
As you would expect, the transfer of an asset previously owned by a limited company to an individual or individuals who are employees or officers of the company (which includes directors by definition) will be treated as a transaction which is prima facie within the scope of the earnings from employment rules in ITEPA 2003. Take the following straightforward example.
Example 1: Transfer of company premises (1)
HQ Trading Limited owns the property from which it trades. The shares in HQ Trading Limited are owned 100% by Mr Director, who is also a director of the company. The company transfers the property to Mr Director and