The latest Finance Bill proposes a number of changes to the substantial shareholding exemption (SSE). These include removing the trading condition for investing companies completely and for investee companies post-disposal (in most cases), extending the qualifying period in which a twelve month substantial shareholding can be held from two years to six and introducing a new exemption for companies owned by qualifying institutional investors. While these changes are welcome and should reduce some of the doubts and complexities surrounding the application of the SSE, there are still a number of issues for practitioners to be aware of when advising clients.
This article was first published in the 20 October 2017 edition of Tax Journal
