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Substantial shareholdings exemption definition

What does Substantial shareholdings exemption mean? A UK corporation tax relief that exempts a company’s gain when it sells a substantial shareholding in another company. In practice, the gain is treated as not a chargeable gain. The regime is statutory: Taxation of Chargeable Gains Act 1992, Schedule 7AC. A “substantial shareholding” generally means 10% or more of the ordinary share capital, with corresponding entitlement to profits and assets, held for a continuous 12‑month period within the previous six years. The exemption can apply to disposals of shares, an interest in shares, and certain assets related to shares. Broadly, the company being disposed of must be a trading...

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UK 2016–17 Budget cycle: Autumn Statement, Draft Finance Bill 2017, Spring Budget and Finance Acts—tax measures, practitioner analysis and legislative progress (Archived)

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Practice notes
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ARCHIVED: This Practice Note is archived and not maintained

This note brings together commentary on the principal milestones in the 2016–17 Budget and Finance Bill process. For a fuller explanation of the annual Budget and Finance Bill cycle, including the procedural steps for enacting a Finance Act, see: Practice Note: The Budget and Finance Bill process.

Finance (No 2) Act 2017

On 8 September 2017, the government introduced the second Finance Bill of 2017 with accompanying explanatory notes, restoring most measures omitted from the earlier Bill. For further detail, see News Analysis: Publication of second Finance Bill 2017.

Earlier, on 13 July 2017, after confirming its plan to legislate for the withdrawn measures, the government issued revised drafting on the corporate interest restriction, hybrid mismatches, the substantial shareholdings exemption, loss reliefs and disguised remuneration. For a comparison of the provisions released on 20 March 2017 with those published on 13 July 2017, see News Analysis: Amended provisions for second Finance Bill of 2017.

The second Finance Bill 2017 received Royal assent on 16 November 2017 and is now known as the Finance (No...

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Web page updated on 22/05/2026

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