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So, if the subsidiary is a trading company which satisfies the ‘substantial’ test, and the holding company has owned the trading sub 100% (50+50) “throughout the period of 2 years ending with the date of the disposal” the disposal should qualify for BADR.
Holding company of a trading group owns all the shares. Dividends are voted upwards to the holding company and distributed to the shareholders. Questions: 1) As long as all the dividends are voted out to the shareholders, my understanding is that the holding company is not classed as associated? For this to apply do these have to be distributed ...
One follow up question I did have - would using management fees instead of dividends have any bearing on the inheritance tax treatment of the "holding company" shares i.e. client dies and leaves shares in holding company to children - if the "holding company" is trading rather than just receiving dividend income would it have any impact on IHT.
Just Google "holding company tax" and you'll find an article I wrote on this. Nishi N-accounting. Thanks (0) Replying to Shamrock: By Shamrock. 19th ...
I have a group made up of a Holding Company and one wholly owned Subsidary, and together their combined turnover, total assets and number of employees are within the Small Entities thresholds therefore classified as a Small Company (no requirement to prepare consoldiated accounts).
The holding company is there purely to receive dividends paid by the trading company that sits underneath it. My client is the director of both companies. My client is the director of both companies. Client (owns 100%) > Holding Company (owns 100%) > Trading Co
A new client has purchased a property holding company, Many thanks. This is achieved by buying the shares of the company, which (in the case of an unquoted company) should be at market values (s.273 TCGA). There are many valuation techniques, and based on the information provided net-asset basis may be appropriate. So, out of the £925 the ...
So has the holding company suffered a loss by acquiring £400,000 of goodwill without paying for it? Most people would call that a profit. If the holding company put the trade back into the subsidiary tomorrow what would the subsidiary be worth then?
My client (Mr B) owns 100% of a dormant holding company (H Ltd). The only asset is an investment in a 100% trading subsidiary (D Ltd). Can we simplify the structure by removing the holding company without causing a tax bill anywhere?
If we sell the shares in the subsidiary company the gain will end up in the holding company attracting tax at marginal rates if distributed and not facilitating use of retirement relief / taper relief for the individual who owns 100% of the holding company . The holding company was set up primarily to protect the properties from trading company ...
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