[2021] UKFTT 0069 (TC)

Judge Ian Hyde

Decision released 12 March 2021

Substantial shareholding exemption – Taxation of Chasrgeable Gains Act 1992, Sch. 7AC – Paragraphs 7 and 15A – Whether relief available when the shares have been owned by a company in a group for less than 12 months – No.

  The First-tier Tribunal held that the chargeable gains substantial shareholdings exemption ownership period could not be extended in relation to trading assets transferred from another group member because the other group member was not a member of the group for whole of the 12-month ownership period.


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