delroy and grant

on 10 january 2016,delroy made a gift of 25000 £1 ordinary shares in dub ltd, an unquoted trading company, to his son grant. the market value of the shares on that was £240000. delroy had subscribed for the 25000 shares in dub ltd at par on 1 july 2005. delroy and grant have elected to hold over the gain as a gift of a business asset.

grant sold the 25000 shares in dub ltd on 18 march 2016 for £240000

dub ltd has a share capital of 100000 £1 ordinary shares.delroy was the sales director of the company from its incorporation on 1 july 2005 until 10 january 2016.grant has never been an employee or a director of dub ltd.

for the tax year 2015/16,delroy and grant are both higher rate taxpayers. they have each made other disposals of assets during the tax year 2015/16, and therefore they have both already utilised their annual exempt amount for this year

what would the cgt implications would have been if delroy had instead sold the 25000 shares in dub ltd himself for £240000 on 10 january 2016, and then gifted the cash proceeds to grant?

1) entrepreneur’s relief would have been available
2) the cgt would have been paid later
3) the cash gift would not have been a chargeable disposal
4) the cash gift would have been qualified for holdover relief