You should really go back a step and ask why have you accumulated funds in a company structure?
@Brendan Burgess Personally, I think there are merits in holding a small level of funds within a company structure, if even for cash flow purposes. Any small company is likely to have peaks and troughs when it comes to business, and particularly cash flow, and therefore many need to hold some levels of cash reserves in it. Its just prudent - no different to a personal rainy day fund.
I think the mistake that is made with close company surcharge is the fact that it should allow a small reserve be built up within a company before the close company surcharge kicks in (say quarter or half of a companies annual expenses as a 'cushion'). This could be formally placed in a particular 'reserve' account on the books, and show movements in and out of it explicitly if needed.
There are reasons people can be looking build funds within a company, especially service companies - whether it being taking some time off after a busy project or wishing to retrain or whatever. This is outside the other reasons including the desire to offset capital losses if they exist or avail of retirement relief, if they are close to that age.
Given the move towards the 'gig/freelance' economy, I personally think close company structures should be encouraged to build a small level of reserves to fund the good with the bad, and therefore smooth out income fluctuations.
I have seen many a new IT contractor have a big smile on their face as they experience the 'jump' in salary as a result of the move from permanent to contract positions, and suffer immediate lifestyle inflation as a result, only to come crashing back down when the contract is not renewed and no cushion is available to smooth the transition between contracts.
