½Û×ÓÊÓƵ

Cases in which SSE applies

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Cases in which SSE applies

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The commentary set out in this guidance note is based on the legislation for disposals on or after 1 April 2017. For details of the regime as it applied before this date, see Simon’s Taxes D1.1071.

SSE ― the main exemption

The substantial shareholding exemption (SSE) applies to disposals of shares and interests in shares by qualifying companies on or after 1 April 2002 and exempts gains from corporation tax in certain circumstances. Conversely if losses are generated by the disposal and the SSE conditions are met, they are not allowable.

Certain requirements must be met in respect of the investee company and the shareholding itself in order for the investing company to benefit from the exemption. The key conditions are as follows:

  1. •

    at the time of the disposal, the investing company must have owned at least 10% of the ordinary share capital of the investee company for a continuous period of 12 months during the six years prior to the date of disposal

  2. •

    from the beginning of the latest period of 12 months for

Continue reading
To read the full Guidance note, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

Tax implications of administration and liquidation

Tax implications of administration and liquidationThis guidance considers the tax implications of a company going into administration or liquidation.Introduction to company administration and liquidationCompany going into administrationA company which is in financial difficulty may go into

14 Jul 2020 15:29 | Produced by Tolley Read more Read more

Overseas property businesses for companies

Overseas property businesses for companiesOverviewReal estate income is generally taxed where the property is located; the UK tax treaties generally allow the jurisdiction where the land is located to tax income from the land.Therefore, a UK company with overseas property may be subject to tax in

14 Jul 2020 12:22 | Produced by Tolley in association with Rob Durrant-Walker of Crane Dale Tax Read more Read more

VAT registration ― artificial separation of business activities (disaggregation)

VAT registration ― artificial separation of business activities (disaggregation)This guidance note should be read in conjunction with the VAT registration ― compulsory guidance note and is relevant to persons established or resident in the UK. Persons that are not established or resident in the UK

14 Jul 2020 13:57 | Produced by Tolley Read more Read more