Commentary

D1.1007 Substantial shareholding exemption—The main exemption

Corporate tax
Corporate tax | Commentary

D1.1007 Substantial shareholding exemption—The main exemption

Corporate tax | Commentary

D1.1007 Substantial shareholding exemption—The main exemption

Under the substantial shareholding main exemption a gain accruing to the investing company on the disposal of shares or an interest in shares (see D1.1065 for the definition of this) in the target company is exempt if the substantial shareholding requirement (see D1.1010) and the requirements relating to the target company (see D1.1031) are both met1.

The main exemption applies on the disposal of shares (or an interest in shares) of any class in the target company2, where the investing company has held a substantial shareholding (broadly, a 10% holding of ordinary shares, but there

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