Originally posted by NotAllThere
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OP Ltd sells its assets and goodwill to X for£Z
OP Ltd now has assets (cash) of £Z (plus anything not sold onto X). This sale has CGT implications of its own related to the companys tax position
OP still owns shares in OP Ltd which is now a cash shell
OP liquidates OP Ltd and makes capital distributions (or just takes dividends etc over X years to run the cash down)
Exactly how and when the transactions take place will govern what relief is available. The "business" is distinct from the shareholders. It would would be harsh if relief were not available, but ascertaining the effect of the transactions before entering into them would be sensible.


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