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The UK government has provided an exemption from tax for trading companies that sell other trading companies for 15 years. The Finance Bill 2017 will remove certain restrictions which have caused practical problems with claiming this exemption from the budget date to simplify the regime, these include:
The combined effect of the changes will be to make it easier for groups with a mixture of trading and investment activities to claim the exemption on disposals of trading companies, and remove the need to rapidly liquidate a holding company after it disposes of its last trading subsidiary.
The exemption applies to both gains and losses, so the changes will restrict the ability of certain companies to claim a capital loss on disposals following the 2017 budget.