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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 / D1.1036 Substantial shareholding exemption—implications of trading requirements for group structures
Commentary

D1.1036 Substantial shareholding exemption—implications of trading requirements for group structures


Corporate tax

The restriction of the SSE) to target companies (and for disposals before 1 April 2017, investing companies), and groups, which are trading(unless the qualifying institutional investor subsidiary exemption is met, see D1.1043) means that consideration needs to be given to the way in which groups comprising an element of non-trading activities should be structured. Possible approaches include:

  1. Ìý

    •ÌýÌýÌýÌý where non-trading activities are relatively insubstantial these could be carried on in the same company as the trading activities, so that the non-trading activities are swamped in proportion to the trading activities, see D1.1033. The company continues to qualify as trading and therefore potentially eligible for exemption

  2. Ìý

    •ÌýÌýÌýÌý non-trading

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