Commentary

D1.1036 Substantial shareholding exemption—Implications of trading requirements for group structures

Corporate tax
Corporate tax | Commentary

D1.1036 Substantial shareholding exemption—Implications of trading requirements for group structures

Corporate tax | Commentary

D1.1036 Substantial shareholding exemption—Implications of trading requirements for group structures

The restriction of the substantial shareholding exemption (SSE) to target companies (and for disposals before 1 April 2017, investing companies), and groups, which are trading for the purpose of TCGA 1992, Sch 7AC (unless the qualifying institutional investor subsidiary exemption is met, see D1.1043) means that consideration needs to be given to the way in which groups comprising some non-trading activities should be structured. Possible approaches include:

  1.  

    •     Where non-trading activities are relatively insubstantial these could be carried on in the same company as trading activities, so that the non-trading

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