Hi Alan, Our client, 100% owner of 3 trading companies, his current structure is, company A owns 100% of the A ordinary shares (golden shares) in companies B and C, essentially a company law group. Inter company loans exist between all companies in the group. To group relief trading losses looking at setting up a tax group whereby a holding company structure is put in place owing 100% of the ordinary shares in companies A, B and C. What are the implications of changing the structure? How best to do this? Thanks, John.
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