Commentary

D7.446 Equities—disposals of substantial shareholdings

Corporate tax
Corporate tax | Commentary

D7.446 Equities—disposals of substantial shareholdings

Corporate tax | Commentary

D7.446 Equities—disposals of substantial shareholdings

The substantial shareholdings exemption is discussed in Division D1.10, the variations applying to life insurance companies being considered in more detail in D1.1010. The exemption does not apply to a deemed disposal under FA 2012, ss 116–118 (transfers of assets held for long-term business between categories or companies, see D7.453)1.

The only further point to note are that while the definition of a substantial shareholding is increased to 30% in the cases of equities held for the purposes of the company's long-term insurance business, that threshold is not relevant if the disposal is of a holding

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