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).

A QII includes any of the following entities:

registered pension funds;

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