Incorporate.ltd
Guide

How to Migrate a Business to a New Corporate Structure Without Triggering Tax (2026)

Key UK reliefs for migrating a business from one structure to another: incorporation relief (sole trader → Ltd company, defer CGT on goodwill transfer), Section 135 share-for-share exchange (insert HoldCo), Section 110 demerger, business asset rollover relief (replace qualifying business assets without CT).

March 2026 5 min read
How to Migrate a Business to a New Corporate Structure Without Triggering Tax (2026)

Key UK reliefs for migrating a business from one structure to another: incorporation relief (sole trader → Ltd company, defer CGT on goodwill transfer), Section 135 share-for-share exchange (insert HoldCo), Section 110 demerger, business asset rollover relief (replace qualifying business assets without CT). Each relief has strict conditions — timing, commercial purpose, and elections matter. This article covers each relief with examples.

Need help choosing the right jurisdiction?

Use our free Country Picker tool or get a personalised consultation.

This content is educational and does not constitute legal or tax advice. Always consult a qualified professional for your specific situation. Data last verified March 2026.