The substantial shareholding exemption (SSE) legislation provides for a number of situations where earlier transactions would, in the absence of a specific provision, unfairly shorten or, in some cases, lengthen the qualifying period of ownership. These are considered below.
Earlier no gain/no loss transfer
Where the investing company acquired shares or an interest in shares by means of a no gain/no loss transfer, its period of ownership is treated as including that of the transferor company and any other transferor in a chain of no gain/no loss transfers1.
The investing company is deemed to have the same entitlement and rights in respect of those shares (or interest in shares), as its predecessor had from those shares or, if relevant, the shares from which those shares derived2. In addition, the share rights that the investing company is is deemed to have can include any shares or rights held by another company which the predecessor could have aggregated under the group provisions in TCGA 1992, Sch 7AC, Pt 2, para 93,
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