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There are some creases in the substantial shareholdings exemption.
KEY POINTS
- 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 activities...
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