The market value of assets transferred on a business incorporation was £1, and the amount actually paid by the company was not a distribution, but the company was not entitled to intangible fixed assets relief on the payment.
Jasper Conran Optical LLP (JCO) was formed and commenced trading in June 2007. It was owned 99.9% by the first appellant (JATC), the remaining 0.1% being held by a company wholly owned by JATC.
JCO was subsequently incorporated as the second appellant
