My client Mr X and his wife are directors and sole shareholders of a property holding company. The company has owned a small estate of commercial warehousing units which they have opted to tax and let to third parties for a number of years. The market value of the properties is significantly higher than their book value. My client is now contemplating the following: selling the units outright to a developer; converting the units into residential dwellings which would then be sold off; or entering into a joint venture arrangement with a house builder to create new houses which would then be sold. Any development would take at least 18 months to complete. What are the tax issues?
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