15.11 Share sales and relief under the substantial shareholdings exemption
In certain circumstances, a corporate landlord may be able to claim CGT relief on a share sale under the substantial shareholdings exemption (SSE). This is a tax relief in respect of chargeable gains made by corporate shareholders.
Until 1 April 2017 the relief was aimed solely at holdings in trading ventures and so was not available for shares held in property investment companies. However, from 1 April 2017 the relief is modified to apply to holdings in non-trading companies, provided that at least 25% of the seller’s ordinary share capital is held by qualifying institutional investors (QIIs).