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SUBSTANTIAL-SHAREHOLDING-EXEMPTION


Demystifying the Substantial Shareholdings Exemption premium
Card image Jennifer Plummer
Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.
28 January 2026
Top ten cases of 2023 premium
Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers. 
13 December 2023
2023: a parting glance in the rear view mirror for corporate tax practitioners premium
Card image Gerald Montagu
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
13 December 2023
M Group Holdings: time for a law change premium
Card image Alistair Godwin
In light of the Upper Tribunal’s recent decision which took a restrictive view of the substantial shareholding exemption rules, a change to the legislation is now required, writes Alistair Godwin (EY).
26 October 2023
Planning for the substantial shareholding exemption following M Group Holdings premium
Card image Robert Langston
The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.
11 October 2023
M Group Holdings Ltd v HMRC premium
Substantial shareholding exemption not available
5 September 2023
Share deals: when is the optimum time to sell? premium
Card image Laura Frenck
Card image Lorna McCaa
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
16 November 2022
Tax and the City review for May 2021 premium
Card image Mike Lane
Card image Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
12 May 2021
Holding shares through partnerships: some observations premium
Card image Jonathan Cooklin
Card image Dominic Foulkes
Dominic Foulkes and Jonathan Cooklin (Davis Polk) share their approach to understanding some of the tax issues.
 
4 October 2018
Encountering intangibles: some practical suggestions premium
Card image Gregory Price

Gregory Price (Macfarlanes) offers some potential solutions to issues that can arise when dealing with intangible assets.

16 May 2018
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