Company tax planning

Produced by

Corporation Tax

Guidance

In addition to considering the tax issues for shareholder, it may be necessary to do some planning for the business to be floated, including:

•
ensuring that all assets necessary to the running of the business are owed by the company, including intellectual property assets (it is not always clear who actually owns these, particularly where the company has grown over a long time) and real estate
•
separating out assets or trade which are not necessary for the business that is to be floated
•
incorporation of the business, where it is not already in a company

This planning should be done as early as possible, to minimise any associated tax costs.

Transfer of assets to the company by shareholders

Where assets used by the company are owned by shareholders, either as a deliberate policy where the premises are owned by a shareholder

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Anne Fairpo

Barrister

With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

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