Commentary

D1.1070 Background to the introduction of the substantial shareholding exemption

Corporate tax
Corporate tax | Commentary

D1.1070 Background to the introduction of the substantial shareholding exemption

Corporate tax | Commentary

Substantial shareholding exemption—Background and pre-1 April 2017 disposals

D1.1070 Background to the introduction of the substantial shareholding exemption

The substantial shareholding exemption (SSE) was introduced in 2002 to bring the UK onto a more even footing with certain other European tax regimes, where exemption from gains was already available for disposals of significant holdings of shares in companies held as active investments (the participation exemption). It applies for disposals of chargeable assets after 31 March 20021.

Before the introduction of the exemption, some UK-controlled groups had held non-UK operating subsidiaries in a Netherlands or other non-UK sub-holding company to enable

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