Jerome, thanks for your reply.
1) but when would I transfer? (It can't be now as I believe they have clauses that I can't sell / transfer them privately)
2) could the share for share exchange somehow be with EMI shares?
4) very interesting, I didn't realize EIS was also CGT efficient. Let's say I had a £100k gain I'd owe %20 or £20k. If I invested the money in EIS shares I might get a %30 rebate so £10k up but a. EIS shares are risky and b. you have to sell them some time (and my understanding is that most of the time EIS shares are for "young businesses" so you have no control of if/when you can actually sell them and you can't exactly slowly sell them to take advantage of CGT allowance)
c) did I understand that correctly?
5) Any other ideas?
Thanks so much for your help!
1. you can transfer beneficial interest under a deed of Trust which may not be in accordance with the purchase agreement although the deed of gift to your partner could mirror your purchase terms and the company would probably never know anyway (you'd still be the legal seller in the future). A properly executed deed of gift should still satisfy HMRC as to who the beneficial owner is.
2. I can't see how you can share for share exchange like for like shares; you'd have to ask your employers advisors since it may be possible if the shares have different rights attaching. I wouldn't get too hung up on this although its worth asking for your employers views.
4. You understood the principals correctly. Next step is to contact a reputable financial advisor. EIS comes with risks but there are pooled investments out there which spread risk. There are some providers that seem to perform well. I can put you in touch with financial advisors if you want so feel free to message me if you want. I don't give investment advice though.
5) Move to the Bahamas!