My client has two trading companies under common control, he wants to extract some money tax efficiently, so he is planning to sell one of the companies to the other and claiming business asset disposal relief (BADR) on the transaction. He meets all of the conditions, would he pay 10% tax on the gain?

If we only look at the BADR rules that may indeed be the case, but the transactions in securities (TIS) of Chapter 1 Part 13 Income Tax Act (ITA 2007) allow HMRC to charge receipts under such transactions to income tax instead.

All the legislation in this article references Income Tax Act 2007 (ITA 2007).