Although corporate transaction activity has been limited due to the economic downturn, groups are now starting to look again at disposing of parts of the business that are non-core. A share sale is usually the most tax-effi cient way for them to achieve this. After ‘packaging’ the business to be sold, key tax aspects of a corporate share sale will be managing a smooth due diligence and sale process and minimising the tax costs of a disposal, usually by taking advantage of the Substantial Shareholding Exemption legislation. The SSE is a relatively simple concept, but in practice there are potential pitfalls which a corporate vendor needs to be aware of to realise a tax-free gain.
