Specialist UK tax advice for Manchester individuals, landlords, directors and businesses
Transactions & reorganisations

Business Restructuring Tax Advice for Company Owners and Shareholders

Selling a company, reorganising share ownership or separating business activities can create Corporation Tax, Capital Gains Tax, Income Tax and Stamp Duty consequences. Tax needs to be considered before the legal steps are fixed.

The commercial transaction comes first. Tax advice should support the deal rather than turn a commercially sensible transaction into a structure designed only around a relief.

business sale tax advice

BADR 18% 2026

company restructuring tax advice

share sale tax planning

Transaction enquiry

Tell us what transaction you are considering

Approximate value and timing are sufficient initially.

Prefer to call? 0800 135 7323

Direct answer

When Is Business Restructuring Tax Advice Needed?

Before shares, assets or business activities are transferred. Once completion occurs, planning options can disappear.

The practical answer

Business Restructuring Tax Advice Should Begin Before Legal Documents Are Finalised

The structure of a share sale, asset sale, reorganisation or demerger affects who is taxed, what reliefs can apply and where the sale proceeds ultimately sit.

Share saleThe shareholders dispose of shares and consider personal CGT reliefs.
Asset saleThe company disposes of assets and extracting the proceeds becomes a separate issue.
ReorganisationShare exchanges and group structures need technical conditions reviewed.
SuccessionFamily or management transfers can involve several tax regimes.
Service scope

Business Transactions We Can Review

Transaction advice can cover a sale, an internal reorganisation or a succession plan.

01 / SALE

Company sale

Share ownership, proceeds, BADR conditions and wider personal tax are reviewed.

02 / ASSETS

Asset sale

Company-level tax and later extraction of sale proceeds are considered separately.

03 / SHARES

Share-for-share exchange

The statutory reorganisation provisions and commercial purpose need to be checked.

04 / GROUP

Holding company insertion

Existing ownership and future commercial objectives are reviewed before implementation.

05 / DEMERGER

Business demergers

Separating business activities requires coordinated tax and legal planning.

06 / SUCCESSION

Succession planning

Family, employee or management succession can require CGT, Income Tax and company-tax analysis.

How the engagement works

From Commercial Objective to an Implementable Tax Structure

01 / OBJECTIVE

Understand the transaction

Ownership, objectives, parties and commercial timetable are established.

02 / MODEL

Model tax outcomes

Alternative sale or reorganisation structures are compared.

03 / RELIEF

Check relief conditions

Relevant reliefs are tested against the actual facts and timing.

04 / IMPLEMENT

Coordinate implementation

Tax advice is aligned with the agreed legal and commercial steps.

2026 business disposal rules

Business Restructuring Tax Advice and the 18% BADR Rate

Business Asset Disposal Relief remains valuable, but the reduced rate is no longer the historic 10% rate.

18%BADR rate for qualifying disposals from 6 April 2026.
2 yearsMany BADR conditions require the relevant conditions to be met throughout a two-year qualifying period.
£1 millionLifetime BADR limit for qualifying gains.
18% / 24%General individual CGT rates can apply where BADR is unavailable.

BADR eligibility should be checked before signing transaction documents. Shareholding percentage, officer or employee status, trading-company status and timing can all be material.

Frequently asked

Business Sale and Restructuring Questions

Is a share sale more tax-efficient than an asset sale?

They tax different parties and produce different commercial outcomes. The buyer's and seller's objectives usually need to be considered together.

What is the BADR rate in 2026/27?

Qualifying BADR gains on disposals from 6 April 2026 are charged at 18%.

Can I insert a holding company without tax?

Potential reliefs may apply to qualifying reorganisations, but the legal steps, consideration and commercial purpose need review before implementation.

Can I separate two businesses before selling one?

Potentially, but demergers and pre-sale restructuring are technical and should be planned before contractual commitments are made.

When should I start sale tax planning?

Before heads of terms become too advanced, particularly where ownership or group restructuring may be needed.

Can you work with the corporate solicitor?

Yes. Tax and legal implementation should normally be coordinated on a transaction.