The SAFO & EEV Combination
Most owners reach a point where they want the company to keep growing without them carrying the entire load. They want continuity, not a cliff edge. They want control over timing, not a scramble. Yet the market often gives only two routes. Sell to an outsider and surrender the legacy. Or hand everything to an Employee Ownership Trust and lock themselves into a rigid statute that treats the founder like a temporary guest in their own company.
The Mural Crown SAFO and the Equity Exchange Vehicle open a different route. Think of it as a flexible gearbox sitting under the business, controlling torque, direction and pace. You can release power gently, hold it steady or shift up when the moment suits you. Nothing forces your hand.
A founder can begin by fixing the value they have created through Freezer shares. That fixed value acts like a locked compartment in the hull. Storms cannot inflate it. Market swings cannot distort it. Whether those Freezer shares carry a coupon or not, the crucial point is that the growth moves elsewhere. Into the next team. Into the next phase of the company’s life.
Once the EEV owns the trading company for at least twelve months, the EEV can gradually buy or redeem those Freezer shares tax-free under Substantial Shareholder Exemption (SSE). Each redemption creates a steady flow of capital into the founder’s SAFO without creating personal tax issues. It feels as though the engine is gently unloading cargo from one vessel to another, all within the corporate harbour where tax rates are calm and predictable.
Then the SAFO becomes the personal pressure valve. If the founder needs to clear a mortgage or deal with a personal liability, they can redeem a portion of their own Freezer shares at Business Asset Disposal Relief rates. Fourteen to twenty-four percent rather than thirty-five point seven five to thirty-nine point three five percent on dividends. Not because they are avoiding income but because they are liquidating fixed value created over years. If they do not need the capital, they simply leave it in the SAFO, where inheritance tax is neutralised through alphabet share structuring.
An EOT cannot offer this kind of choreography. Under an EOT, the founder must step away quickly, take their money once and accept that the rules lock the structure in place forever. The EEV avoids these limitations. It allows the founder to exit the trading company at a controlled pace while employees and the management team gain genuine majority control over time. No forced schedule. No single jump from ownership to retirement. The handover becomes a sequence of controlled steps, each supported by tax rules that treat the business as a continuing organism rather than a one-off event.
And something else happens. The SAFO becomes the vault where the founder’s fixed value settles. If they never need the money personally, the Freezer shares in the SAFO can pass to the next generation without inheritance tax. One transition, the business transition. Another transition, the wealth transition. The same framework handles both. No need to solve one and accidentally create a fresh problem.
This is why the SAFO and EEV combination feels like a tax-free zone for strategy rather than a one-dimensional exit tool. You can separate continuity from succession. You can separate personal liquidity from legacy. You can manage the company’s leadership transition over several years and then complete the inheritance plan on your own timeline. Nothing collapses into crisis. Nothing has to be rushed because of tax rules.
Imagine standing at the helm of a long-range vessel, knowing you can lock specific containers, release others, refuel mid-ocean, and hand the wheel to the new crew only when they are ready. That is how the SAFO and EEV work together. A founder can remain involved until the team is strong enough. They can reduce involvement without abandoning control. They can avoid the compressed deadlines that an EOT forces on them. And they can plan decades without triggering personal liabilities.
The structure respects both sides of the founder’s mind. The entrepreneur who built something worth protecting. And the parent who wants to hand the next generation a functioning institution rather than a tax riddle.
When the transition is complete, the trading business will be run by the people who run it. The wealth created over a lifetime will sit in the SAFO. The founder’s debts or obligations will have been handled at low tax cost if needed. And the entire arrangement will have grown organically rather than violently.
This is not clever accounting. It is simply using the corporate world’s own rules to build continuity on your terms. The EEV and SAFO give you room to think. Space to pace your decisions. Freedom to sequence events rather than react to them.
If you want a structure that lets your business and your family plan across decades rather than tax years, this pairing is the closest thing to complete freedom available within UK law today.
