Commentary

D1.1040 Substantial shareholding exemption—overview of the subsidiary exemptions

Corporate tax
Corporate tax | Commentary

D1.1040 Substantial shareholding exemption—overview of the subsidiary exemptions

Corporate tax | Commentary

Substantial shareholding exemption—The subsidiary exemptions

D1.1040 Substantial shareholding exemption—overview of the subsidiary exemptions

There are three subsidiary exemptions to the main exemption.

  1.  

    •     The first subsidiary exemption applies to disposals of assets related to shares; that is, options over shares, securities with rights to convert into or acquire shares, and options over such securities1, see D1.1041.

  2.  

    •     The second subsidiary exemption applies where the conditions for exemption are not satisfied at the time of the disposal of either shares or assets related to shares, but would have been satisfied if the disposal had taken place up to two years

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