Substantial shareholding exemption (SSE) ― overview

Produced by a Tolley Corporation Tax expert

Corporation Tax

Guidance

The substantial shareholding exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. No claim is required. Provided the conditions for SSE are met, it applies automatically. Conversely, if losses are generated by the disposal and the SSE conditions are met, the losses are not allowable.

There is no ability to disclaim the exemption (for example, where it would be advantageous to claim a loss).

The exemption is aimed at disposals by companies of investments in trading companies, groups and subgroups.

Ensuring the conditions for SSE are met is extremely important as the financial value of the exemption can be significant. Conditions are in place relating to both the investing company and the investee company. The rules are complex and, in particular, HMRC will often scrutinise the activities of the company / group / sub-group disposed of to establish whether the trading activity tests

Access this article and thousands of others like it
free for 7 days with a trial of TolleyGuidance.

TAKE A FREE TRIAL

Popular Articles

Employment Tax

Fuel-related payments / mileage payments

Fuel-related payments / mileage paymentsIntroductionMost employers will make payments to employees in relation to business travel. Among the most common payments in relation to business travel are fuel and mileage payments. If an employer does not reimburse these amounts, then the employee will be

14 Jul 2020 11:46 | Produced by Tolley in association with Philip Rutherford Read more

Employment Tax

Non-business expenses

Non-business expensesIntroductionIn order for an expense to be tax deductible it must be incurred because of an employee’s employment. Any non-business related expense is, therefore, not relievable except in some very particular circumstances.This guidance note deals with three separate issues. The

14 Jul 2020 12:16 | Produced by Tolley Read more

Owner-Managed Businesses

Furnished holiday lets

Furnished holiday letsThis guidance note sets out the qualifying conditions for a property let to be treated as a furnished holiday let (FHL) for tax purposes and the subsequent tax implications.Whether or not a property qualifies as an FHL can make an important difference to the taxation

14 Jul 2020 11:46 | Produced by Tolley Read more

Spring Budget 2024

UU��ֱ��