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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.10 Substantial shareholding exemption /Substantial shareholding exemption—the subsidiary exemptions / D1.1043 Substantial shareholding exemption—the third subsidiary exemption—qualifying institutional investors
Commentary

D1.1043 Substantial shareholding exemption—the third subsidiary exemption—qualifying institutional investors

Corporate tax

There are three subsidiary exemptions in addition to the main SSE. The first subsidiary exemption is discussed in D1.1041, the second subsidiary exemption is discussed in D1.1042 and the third is set out below.

The third subsidiary exemption applies to disposals on or after 1 April 20171, where the following conditions are met:

  1. Ìý

    •ÌýÌýÌýÌý the substantial shareholding condition is met2, see D1.1010

  2. Ìý

    •ÌýÌýÌýÌý the requirements relating to the target company (broadly, that it is trading) are not met3, see D1.1031

  3. Ìý

    •ÌýÌýÌýÌý the investing company is not a disqualified listed company4, and

  4. Ìý

    •ÌýÌýÌýÌý at least 25% of the ordinary share capital of the investing company is owned by qualifying institutional investors5

These provisions apply to exempt a gain or disallow a loss in whole or in part, depending on the proportionate interest held by the qualifying institutional investors as follows:

  1. Ìý

    •ÌýÌýÌýÌý where 80% or more of the ordinary share capital in the investing company is held by

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