How does SSE interact with other legislation?

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

The substantial shareholdings exemption (SSE) is often just one factor to consider in the context of a transaction to sell the shares in a company. As part of the tax structuring for this type of transaction, a number of other tax-related provisions must be analysed to ensure the most tax efficient result is achieved, balanced with any commercial factors. For more in-depth commentary on SSE, see Simon’s Taxes D1.1045, D1.1061. See also the Tax implications of share sale guidance note.

For a flowchart showing when SSE is available or when other legislative provisions take priority in particular transactions, see Flowchart ― SSE ― When does SSE apply with share reorganisations and intra-group asset transfers?.

SSE and the degrouping charge

SSE available to exempt de-grouping charges

The investing company and the target company may have been members of the same group for capital gains purposes, but if the investing company sells its shares in the target company, the group relationship will be broken. Assets may have been transferred between the group companies prior to the group relationship

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