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Draft Finance Bill 2017 rules on the substantial shareholdings exemption

Trudy Armstrong (PwC) explains the proposed reforms to the SSE regime and examines their practical impact.
 
Further to the recent consultation on potential reform of the substantial shareholdings exemption (SSE) the draft provisions for inclusion in Finance Bill 2017 which were published on 5 December 2016 propose various amendments to the existing rules. The changes which apply to disposals on or after 1 April 2017 are very positive. If enacted as proposed the changes should result in the regime being easier to apply in practice and more widely available.
 

Recap on the rules and the consultation

 
SSE applies to a disposal by a company of shares and certain related assets. Where one company (‘the investor’) sells shares in another company (‘the investee’) any gain arising will be exempt from tax if the...

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