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Ironing the wrinkles

21 June 2016 / Pete Miller
Issue: 4555 / Categories: Comment & Analysis

There are some creases in the substantial shareholdings exemption.


  • Until 18 August HMRC is consulting on the substantial shareholdings exemption.
  • A summary of the conditions for the relief.
  • The document recognises that there are aspects of the present relief that put the UK at a disadvantage.
  • A number of options for change are put forward by HMRC in the document.
  • Problems arise if shareholdings are held by corporate partners in a partnership or a company has no share capital.

HMRC published a consultation document on the reform of the substantial shareholdings exemption (SSE) on 26 May. The consultation closes on 18 August at 11.45pm – which seems remarkably specific. The document acknowledges that the exemption – designed to ensure that tax is not a barrier to investment or disposal of trading...

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