Partition Group Family Business - FinTax
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Partition Group Family Business

About This Project

Family owned & managed business operated through a group structure since 2002. The group had 3 separate business operated by individual family members. The directors of the company wanted to partition the group into 3 separately owned business and partition away from the current holding structure.


To facilitate the partition of the business the existing capital structure of the group holding a number of steps had to be taken with the objective of obtaining advance approval from Revenue for the partition of the group:

  1. Transfers of assets within the group to align the balance sheets correctly for the companies that were to be partitioned from the group.
  2. The issued share capital in the holding company re-designated so that separate share classes to be created that attached ownership to a particular shareholder for the required subsidiary company.
  3. New holding companies set up to acquire ownership of subsidiary company by way of share for share exchanges to the shareholder of each individual share class in the existing holding company.
  4. Submitting the partition proposal to Revenue seeking advance approval that the partition did not involve “value shifting” between shareholders on re-designated share capital and partition qualified for capital gains tax relief under Revenue precedent 701.


The outcome was Revenue approval on the “group partition” with no capital gains on partition of the group and no value shifting or distribution issues for company shareholders. The companies were under separate ownership after the partition with each owner free to manage their company independently from the main group.