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Reform of the substantial shareholdings exemption

A consultation considering possible reform of the substantial shareholdings exemption, with a view to increasing its simplicity, coherence and international competitiveness.

Last fetched 03 May 2026 · gov.uk
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At Budget 2016, the government announced that it would consult on possible reform of the substantial shareholdings exemption, with a view to considering whether there could be changes to make it simpler, more coherent and more internationally competitive.

In line with that announcement, this consultation sets out a number of options for possible reform, ranging from technical changes to the existing SSE legislation to a more comprehensive corporation tax exemption for gains on substantial share disposals that corresponds with regimes in place in other countries.

The consultation considers the impact of these reforms and the potential benefits for the UK economy.

It also considers the potential risks associated with reform and how these risks could be adequately be protected against.

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