Taxation of Chargeable Gains Act 1992 Schedule 7AC paragraph 17

Special rules for assets of insurance company held for the purposes of its long-term business

Section 17 modifies the substantial shareholding exemption rules for insurance companies by raising the qualifying threshold from 10% to 30% for shares held as part of long-term business, and by restricting the aggregation of group company holdings in certain circumstances.

  • The substantial shareholding threshold is increased from 10% to 30% where an insurance company disposes of shares held for the purposes of its long-term business
  • The same 30% threshold applies where the investing company is a 51% subsidiary of an insurance company and the insurer holds its interest in the investing company (directly or indirectly) as a long-term business asset
  • Shares held by an insurance company for its long-term business cannot be aggregated with other group company holdings when determining whether the substantial shareholding test is met
  • Assets forming part of the insurance company's long-term business fixed capital are excluded from these special rules and are instead subject to the normal 10% threshold

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