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HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: interpretation - interest in shares

TCGA92/SCH7AC/PARA29

Paragraph 29 Schedule 7AC TCGA 1992 explains what is meant for the purposes of the substantial shareholdings exemption legislation by an ‘interest in shares’. References to an interest in shares are to an interest as co-owner of the shares. It does not matter whether the shares are owned jointly or in common. Nor does it matter whether the co-owners have equal or unequal interests in the shares.

Where shares are held through a partnership (including a Limited Liability Partnership where TCGA92/S59A applies) then paragraph TCGA/SCH7A/PARA8(1) means that shares are treated as being held based on the proportionate interest in the partnership, see CG45110.