The following is taken from a document originally published on the HMRC website in June 2002 following the introduction of the Substantial Shareholding Exemption.


These three examples explain how the substantial shareholdings provisions contained in Schedule 7AC TCGA 1992 apply in relation to share reorganisations, particularly within groups of companies.

Examples 1 and 2 illustrate below how the legislation operates in two different types of intra-group transaction. Example 3 shows how the legislation applies to a share exchange outside a group.

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