Annette Morley provides a refresher guide on this key relief.
The substantial shareholding exemption (SSE) was introduced in FA 2002. Its main legislation is found at TCGA 1992 Sch 7AC. FA 2011 Sch 10 brought in important additions relevant to hive-downs and the de-grouping charge changes.
The SSE legislation is complex yet key to corporate transactions and streamlining. This article aims to remind us of the original and integrate the new.
The basic principles
Grasping the nettle of SSE is probably best done in steps. The main exemption is set out at Sch 7AC para 1(1) and simply states that a gain accruing to a company on a disposal of shares or an interest in shares in another company is not a...
