The future of the SSE

06 December 2016

Two fundamental changes are being made to the substantial shareholding exemption (SSE) with effect from April 2017:

Investment companies - not just trading groups - will be able to benefit from SSE on the disposal of a 10%+ stake in a trading company
Companies that are at least 25% owned by qualifying institutional investors will be eligible for exemption (or partial exemption) on the disposal of any substantial shareholding irrespective of whether the underlying company is trading.
In addition, some more minor relaxations are being made to the other conditions contained in the SSE legislation.

The changes were announced at the Autumn Statement on 23 November 2016 and draft legislation was published on 5 December 2016.