The substantial shareholdings exemption (SSE) is often just one factor to consider in the context of a transaction to sell the shares in a company. As part of the tax structuring for this type of transaction, a number of other tax-related provisions must be analysed to ensure the most tax efficient result is achieved, balanced with any commercial factors. For more in-depth commentary on the SSE, see Simon’s Taxes D1.1045 and D1.1061. See also the Tax implications of share sale guidance note.

For a flowchart showing when the SSE is available or when other legislative provisions take priority in particular transactions, see Flowchart ― SSE ― When does SSE apply with share reorganisations and intra-group asset transfers?.