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Back to basics: Substantial shareholdings exemption

Speed Read: Gains on shares held by companies are exempt from corporation tax provided that not less than a 10% stake has been held for 12 out of the last 24 months of ownership. Both companies must be trading companies (or members of a trading group) throughout the 12-month holding period and immediately after the disposal. Losses on the sale of a 'substantial shareholding' are not allowable. Ownership periods of all group companies are aggregated to determine whether the conditions have been satisfied. Substantial shareholdings are transferred within a capital gains group on a no gain no loss basis.
On a disposal of a qualifying shareholding by a company any gains arising are...

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