D1.1031 Substantial shareholding exemption—the target company requirements
Broadly, the conditions relating to the target company (the company invested in) require trading status throughout a specified period. Note that if the target company requirements are not met, it is still possible to qualify for SSE under the third (qualifying institutional investor) subsidiary exemption (see D1.1043) and if the target company has ceased trading in the last two years then the second subsidiary exemption (see D1.1042) may exempt the disposal.
For the main SSE, a qualifying target company is1:
- Ìý
•ÌýÌýÌýÌý a trading company (see D1.1032)
- Ìý
•ÌýÌýÌýÌý the holding company of a trading group (see D1.1033), or
- Ìý
•ÌýÌýÌýÌý the holding company of a trading subgroup (see D1.1034)
It must be a qualifying company throughout the period which starts at the beginning of the 12-month period for which the substantial shareholding requirement is met (see D1.1010) and ends at the time of the disposal2. The end date of this period is modified by the qualifying asset holding company (QAHC)
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Web page updated on 17 Mar 2025 16:02