The government is consulting until 18 August 2016 on options for the reform of the substantial shareholding exemption from corporation tax. This addresses concerns that the complexity of the exemption may be harming the UK’s competitiveness as a holding company location, given changes in both domestic and international taxation since its introduction in 2002. The options include:
· a comprehensive exemption for share disposal gains, subject to tests for trading or otherwise at investee level;
· changes to the existing framework with amended trading tests at investor and investee level; or
· changing the definition of substantial shareholding to include shareholdings of less than 10% or a minimum invested capital requirement.
The government is consulting until 18 August 2016 on options for the reform of the substantial shareholding exemption from corporation tax. This addresses concerns that the complexity of the exemption may be harming the UK’s competitiveness as a holding company location, given changes in both domestic and international taxation since its introduction in 2002. The options include:
· a comprehensive exemption for share disposal gains, subject to tests for trading or otherwise at investee level;
· changes to the existing framework with amended trading tests at investor and investee level; or
· changing the definition of substantial shareholding to include shareholdings of less than 10% or a minimum invested capital requirement.
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