Case study ― ownership of the trading premises

Produced by Tolley in association with of Crane Dale Tax, part of AMS Group

Owner-Managed Businesses

Guidance

The key choices

Looking at a case study example this guidance note covers high level tax issues and planning around scenarios involving the trading premises of a business. The premises could be held inside or outside of the trading entity, in a group company or held personally by the shareholders.

The case study

Rogers Ltd, a trading company, is owned 50:50 by Ginger and Fred who are married to each other. Ginger and Fred personally own the trading premises. They acquired the premises in 2003 at a cost of £200,000. The premises are now worth £800,000. Rogers Ltd is worth £4m, though £500,000 of that is surplus cash which is not earmarked for expansion or any other trade purpose. Ginger and Fred transfer the property into Rogers Ltd for cash consideration of £400,000 in May 2025.

The capital gain on their transfer of the property is £600,000. Of this, only £400,000 is cash consideration, meaning that the difference of £200,000 can be held

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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