The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
The substantial shareholding exemption (SSE) applies to disposals of shares and interests in shares by qualifying companies on or after 1 April 2002 and exempts gains from corporation tax in certain circumstances. Conversely if losses are generated by the disposal and the SSE conditions are met, they are not allowable.
The commentary set out in this guidance note is based on both the legislation for disposals on or after 1 April 2017. For details of the regime as it applied before this date, see Simon’s Taxes D1.1071 (subscription sensitive).
The investee company and the shareholding itself must satisfy certain requirements in order for the investing company to benefit from the exemption, as set out in the Overview of the substantial shareholding exemption guidance note; however, the key conditions are summarised below:
The investing company must also be entitled to:
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