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Family Companies: Tax Issues in Shareholding Structures

Shared from Tax Insider: Family Companies: Tax Issues in Shareholding Structures
By Peter Rayney, March 2026

Peter Rayney reviews the key tax issues that affect the structuring of shareholdings in a family company 

Companies are often set up in a hurry with no real thought being given to the commercial and tax efficiency of their shareholding structures.  

For various personal reasons, some family company ‘owners’ prefer to hold all the shares. As far as they are concerned, this gives them ‘total control’. In practice, overall control can be enjoyed by holding at least 75% of the voting rights, since this would enable the ‘owner’ to pass special resolutions, vary its constitution and put it into liquidation. For effective day-to

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