Closing a company down will be a transaction which is commercially driven but can have significant tax implications. The closure of the company may be because it can no longer continue to trade or it may be that the company is successful but the owners are going to retire from running the business and want to realise the profits and assets in the company.
An alternative to closing a successful company could be to sell the trade and assets out of the company and then set up a family investment company (FIC) which manages the proceeds realised from the sale or assets already held by the company. This allows the current owners to pass the value of the business down to future generations but also provides them with an income stream. For more details, see the Family investment company (FIC) guidance note.
Note that if any usual payments
Allowable expenses for property businessesGeneral itemsMany of the principles applying to allowable expenses for property businesses are similar to those that apply for trading and the rules for individuals in a property business are generally the same as for companies with some exceptions which are
Spouse exemption from inheritance taxArguably, the most important inheritance tax exemption is the spouse exemption from inheritance tax.There is no IHT to pay on gifts from husband to wife and vice versa, or from one civil partner to the other (referred to collectively in this note as ‘spouses’).
Taxation of loan relationshipsThe vast majority of companies will have loan relationships and so will need to consider how they are taxed under the loan relationship rules. There are also specific provisions dealing with relevant non-lending relationships and other deemed loan relationships.