Taxation of Chargeable Gains Act 1992 Schedule 7AC paragraph 9

Aggregation of holdings of group companies

Paragraph 9 deals with how shares held by different companies within the same group are aggregated when determining whether the substantial shareholding requirement is met for the purposes of the substantial shareholding exemption.

• When assessing whether a company meets the substantial shareholding test, shares held by all members of the same group can be pooled together and treated as if held by the disposing company.
• A group member is treated as holding any shares or interests in shares held by any other company in the group.
• A group member is also treated as having the same entitlement to any rights that another group company enjoys by virtue of holding those shares or interests in shares.
• This aggregation rule does not apply to shares held as assets of a long-term insurance fund of an insurance company.