Gains arising on disposals of a substantial shareholding are exempt and losses are not allowable. This document discusses these rules in detail, together with the conditions that need to be satisfied by the investing company and the investee company. It also covers the detail on the joint venture companies; and the qualifying institutional investors.

Points discussed within this guidance note:

> Reform of SSE

Substantial shareholder exemption new rules apply to qualifying disposals made on or after 1 April 2017. The changes aim to remove uncertainty in many situations as well as allowing substantial shareholdings exemption in a much wider set of circumstances.

> The investing company conditions

The investing company conditions are removed in the reformed Substantial Shareholding Exemption rules. This section deals with the legislation applicable to transactions occurring up to and including 31 March 2017.

> A trading company

> A qualifying group

> 51% subsidiary

> Ordinary share capital

> Other group matters

> The qualifying period

> The investee company

> Trading sub-group

> Joint venture companies

> Qualifying institutional investors

> Practical points


To view the full guidance note register for a free trial or if you already have access to TolleyGuidance please use the 'login' button below:

Request a Free Trial to TolleyGuidance to gain access to the full article

TolleyGuidance is produced by specialists within the field, our tax guidance materials provide actionable insights and practical guidance to support you day-to-day. We don’t just inform you about the latest changes in the tax world. We take the time to explain the implications and, most importantly, what actions you need to take for your clients.


A bit about you:

Please note that all fields marked with a * must be filled in
Salutation
First name*
Last name*
Company*
Job title*
Email*
Phone*
Postcode