A and B own a commercial building which for sound personal reasons they wish to transfer to their company. The building’s value is £1m, which the company will be to A and B.
They wish to transfer it to the company over four tax years namely January and April 2018 and Aprils 2019/20.
By transferring the building in quarter shares in this way, they will have eight annual CGT exemptions which will go a long way towards covering their capital gains.
Bearing in mind that the clients control both sides of the transaction, and are not bound to implement the second, third or fourth transfers each of a quarter share of the building, is stamp duty payable on each occasion on £250,000, or is it calculated on the full £1m? If the latter, at what point would it be payable?
Beverley S. Warrington