I own 100% of a company formed as a special purpose vehicle to hold ownership and rent three properties. When my wife and I no longer need the income from this, I wish to pass control and the benefits to my children. Can this be done tax-efficiently and benefit from a holdover agreement by forming a trust for it (even though the company currently owns the property)? 

Arthur Weller replies:  

Quite possibly, the transfer of the shares in this company will trigger capital gains tax (CGT). You could wait until you die and then pass the ownership of the shares to your children as an inheritance without CGT. Alternatively, if you want it transferred sooner than that, you could put the shares into a trust using gift holdover relief to defer the CGT. Then, after at least three months, the trust could transfer out the shares to your children, again using gift holdover relief. This is the theory; however, I would not recommend doing anything without taking proper tax advice from a suitably qualified tax adviser.