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HMRC's clarifications on the substantial shareholdings exemption are welcomed by PETE MILLER
KEY POINTS
- The substantial shareholdings exemption in TCGA 1992 Sch 7AC.
- Defining a trading group in Sch 7AC para 26.
- Is a company without share capital a group member for the exemption?
- Joint ventures Sch 7AC para 24 and the question of trading activities.
- Non-qualifying joint venture holdings merit special attention.
On 2 August 2011 HMRC published Revenue & Customs Brief 29/11 which clarified two aspects of the substantial shareholdings exemption relating to entities without share capital and joint ventures.
This article explains the background to the brief and looks at some scenarios.
Just to recap the substantial...
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