Good morning.
I have just taken on a new client who has a stack of shares in the same UK plc.
He and his wife have no other income using up their personal allowances.
The shareholdings could be sold at a loss due to the current value.
I am considering them selling the shares to a newco of which they would be the only directors.
The sale would obviously be at market value and create a significant loan from the directors which could be drawn down at will free of charge.
Dividends could be taken from the new coy up to the personal allowance and 0% band of £5000.
The dividends received by newco would not be subject to CT.
Obviously there would be a potential annual loss of CGT exemption each year.
The loss on sale would be a "clogged loss".
Subject to that, am I missing anything?
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