Hello
I have a situation where a Limited Company which is owned solely by 1 shareholder who is also sole director, has an asset which the director is looking at transferring to himself. The asset relates to an Overage agreement and relates to some land which may be sold in the future. If and when the land sells for development, then currently it is the company which will receive the amount of the overage.
Question-As the value is unknown and uncertain at this point then what are the company tax implications of making a transfer now at a NIL value? The problem is that we don't know for definite what this amount will be but concerned that as its a connected party transfer there is a chargeable gain arising on the company. Normally a transfer of an asset to it's director would be at MV so how would this transaction be dealt with for tax for the company and individual?
(The director wishes to transfer the asset for IHT planning purposes)
Thank you for any guidance given
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