D1.1061 Substantial shareholding exemption—interaction with other reliefs
There are a number of other reliefs from tax and deferrals of tax arising on chargeable gains. Details of how these interact with SSE are set out below.
Degrouping charge and share disposal
Where a company leaves a group as a result of a disposal of its shares, any degrouping gain or loss will not arise in the company leaving the group1. Instead, the disposal consideration received by the company making the disposal is increased by the amount of the degrouping gain or the allowable expenditure is increased by the amount of the loss2. Therefore the amount of any gain/loss, calculated by reference to the deemed disposal, accrues to the group company making the disposal of shares. If the vendor's gain on the share disposal qualifies for SSE, so does the de-grouping charge added to it.
Where a company leaves a group as a result of a reconstruction falling within the statutory definition of a reorganisation (ie falling within the provisions of
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