Question: I have a company X that is looking to dispose of its shareholding in Z in the near future and I am a little nervous about the application of the substantial shareholdings exemption (SSE). The group structure is as set out in the diagram [to follow].
Answer: The substantial shareholdings exemption (SSE) applies where three main conditions are met which in broad terms are as follows:
1. the vendor has held shares or an interest in shares in the target company by virtue of which it has at least a 10% interest in that company throughout a 12-month period beginning not more than two years before the disposal date;
2. the vendor has been a sole trading company...
