Bespoke demerger structure for a family-owned property group
A £30 million family-owned property group needed to be divided following a breakdown in the relationship between two siblings, each with a significant interest in the business.
We designed a bespoke demerger structure that enabled the family interests to separate cleanly, while minimising the potential capital gains tax and other tax liabilities associated with the transaction. We also secured HMRC clearance to provide certainty before the demerger proceeded.
The result was a successful separation, with each sibling taking control of their own corporate vehicle. The £30 million property split incurred just £50,000 of stamp duty, with no capital gains tax or unexpected tax liabilities arising.
The challenge
A family-owned property group worth around £30 million had reached a breaking point. Two siblings, each owning 45%, had fallen out over the future of the business.
Their mother held the remaining 10%, which she passed to the sister, which created more issues and a need for both sides to go their separate ways.
But dividing a group of this size isn’t straightforward. Without the right structure, they risked crystallising capital gains tax (CGT), stamp duty and other significant liabilities.
They needed a solution that would allow each family member to take their share – fairly, cleanly, and tax-efficiently.
What we did
We designed and delivered a bespoke demerger structure that separated the family interests while keeping tax exposure to an absolute minimum.
Our team:
- Advised on a new clean structure for both families post demerger that allowed the split to happen without triggering CGT
- Secured formal clearance from HMRC to give the family full peace of mind
- Structured the transaction so that the only tax payable was stamp duty – at just £50,000 on a £30 million property split and transfer
Because the demerger involved shares rather than property, we were able to mitigate tax efficiently while achieving the clean separation everyone wanted.
The result
The result was exactly what the family hoped for:
- Each sibling now owns and controls their own corporate vehicle, free to operate independently
- No capital gains or unexpected tax liabilities were experienced
- Just £50,000 in stamp duty, a fraction of what they might otherwise have paid
A sensitive situation resolved through smart structuring, clear communication and technical precision, proving that even complex family business splits can be handled efficiently and harmoniously.
Contact Jake
