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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.10 Substantial shareholding exemption /Substantial shareholding exemption—requirements to be met by the target company / D1.1031 Substantial shareholding exemption—the target company requirements
Commentary

D1.1031 Substantial shareholding exemption—the target company requirements

Corporate tax

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:

  1. Ìý

    •ÌýÌýÌýÌý a trading company (see D1.1032)

  2. Ìý

    •ÌýÌýÌýÌý the holding company of a trading group (see D1.1033), or

  3. 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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