Transferring property to a company to create a loan account

The reduction in the rate of capital gains tax means that anyone holding property assets may well look to retain personal ownership. The 18% rate of CGT looks very favourable when compared with the 22% company tax charge (in addition to the tax on extraction). However one point worth bearing in mind is the possibility to create a directors loan account with a company. By transferring a property to a company, and keeping the proceeds outstanding as a loan from the company, this would allow you to extract cash from the company in the future free of income tax and NIC. Of course the transfer to the company would incur a CGT charge (with proceeds deemed to be the market value), however this would be an 18% tax charge on the gain arising which would then allow the proceeds to be extracted free of income tax (saving tax at 20-40% compared with personal ownership). There would also be any potential SDLT to take into account but nevertheless if there were properties held which have a low gain and high value, a transfer to a company could be tax efficient particularly if any disposal is unlikely (or if the shares could be sold).