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3T and the SSE
Key points
- The substantial shareholding exemption is examined at principles level for ATT paper 4.
- An awareness of the provision is expected without knowing the full details.
- The trading ten per cent and twelve month conditions.
- If the conditions are met chargeable gains will be exempt and capital losses will not be allowable.
- The exemption is automatic if the conditions apply and there is no ability to disclaim it.
Readers with an interest in 1990s pop music may recall the boyband that Michael Jackson’s nephews formed – and this could help tax students remember the conditions for the substantial shareholding exemption. This topic is examined at principles level for ATT paper 4 which means ‘you will be expected to have an awareness that a provision exists and its main thrust without necessarily knowing the details of the provision.’
Below I have set out a typical conversation that I might have...
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