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Holdco setup a sub and introduced €20k of funds to cover costs and development and setup. However when the company was formed the €20k was introduced by way of share capital, the project that was intended for this subsidiary is not going ahead and they want to strike the company off however the company has €20k in cash and share capital so a VSO isn't an option, an MVL would be more expensive and would trigger a CGT liability on the distribution and If the holdco buys back the shares it looks as though tax will apply because the participation exemption also doesn't apply (less than 12 months). is there an option to buyback the shares and strike off the company without triggering a tax liability considering that the company has never traded. The only other option I could see is if we amend the share capital structure with the CRO. Thanks in advance

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Asked on 16 October 2017 12:24 pm