My client set up a new company in 2009 as the vehicle for a management buyout of his parents’ trading company for consideration of £240k in the form of an issue of qualifying corporate bonds (QCBs). HMRC clearance was obtained in respect of the share-for-QCB exchange such that the gain was deferred until the QCBs were redeemed or disposed of at which point it was anticipated that cash would become available to pay the capital gains tax (CGT). The parents then retired and it had been hoped that the QCBs could be redeemed when future profits permitted. However the business has not fared well over the last three years and a decision has been reached to sell off all remaining stock...
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