Client operated a successful retail business and commercial property that it rented. An offer was received from property developer for commercial property. Client wanted to realise the value from the property sale directly rather through the existing company.
To separate the retail business from the investment assets, the retail business was transferred out a new company. The tax reliefs that apply to corporate restructuring were applied with the new company issuing shares to the existing shareholders with the retail trade being transferred to the new company.
Investment assets & retail assets were still ultimately owned by the same shareholders but through independent commonly owned companies.
The shareholders sold the share capital of the investment property company to the developer and realised the gain directly avoiding a double bite of taxation if the company had sold the property and the shareholders distributing the proceeds from the company.