How loans can deny the Substantial Shareholding Exemption (SSE)

The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the shareholding is at least…

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Can a company holding alphabet shares benefit from the Substantial Shareholdings Exemption (SSE)?

The Substantial Shareholding Exemption (SSE) can be a valuable relief when a company sells shares in a trading company (which I will refer to as “target”). If certain conditions are met, then any gain in respect of the share disposal is not subject to tax. Otherwise, it would be taxable at 25%, so the stakes are high.

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Avoid earnouts when substantial shareholding exemption is available

The substantial shareholding exemption (SSE) is a useful corporation tax relief which exempts corporate sellers from paying corporation tax on the…

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