Substantial Shareholdings Exemption



“Excellent course, very engaging speaker”
Mr McCafferty, DC Consulting

Introduction

The substantial shareholdings exemption was introduced in 2002. The rules effectively allow trading companies and groups to sell shareholdings in other trading companies and groups without suffering a charge to corporation tax on chargeable gains.

The legislation is complex and detailed, and this half-day seminar will take you through the rules, from the basics to more advanced areas, and give both technical insights and practical advice on their application of the rules for your corporate clients.

What You Will Learn

This seminar will cover the following topics:

  • The basic rules
    • The substantial shareholding requirement
    • Requirements for the investing company
    • Requirements for the investee company
    • Groups, consortia and joint ventures
  • Trading and non-trading activities
    • The rules
    • HMRC’s interpretation
    • Is cash a problem?
  • Reorganisations, reconstructions, changes of ownership and the SSE
    • Interaction with degrouping charges
    • SSE and reorganisations/reconstructions
    • Changes of ownership issues
    • Some problem areas
  • Practical issues
    • How to ensure the conditions are satisfied
    • Non-UK entities
    • Ordinary share capital
  • Other aspects
    • Subsidiary exemptions
    • Liquidations and the SSE
    • The anti-avoidance rule
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