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Intra-Group Share Exchanges Involving Substantial Shareholdings

 
Nigel Doran tax partner at Macfarlanes points out that the recent substantial shareholding legislation needs clarifying
 
It is clear from a paper posted on the Inland Revenue website in June 2002 that the Revenue intended the transfer of a substantial shareholding from one member of a chargeable gains group to another in exchange for shares issued by that other member to fall within the 'no disposal' provisions of TCGA 1992 s 127 (as applied by s 135) rather than the substantial shareholding exemption or the 'no gain no loss' provisions of TCGA 1992 s 171(1). However the substantial shareholdings legislation does not make this at all clear. Rather to achieve this objective it opts for the perilous drafting technique of deeming or assuming a state of...

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