This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: the trading company/group/subgroup requirements - as soon as is reasonably practicable in the circumstances


Rather than impose a fixed time limit, the legislation allows companies whatever time is reasonable, having regard to the particular circumstances, to prepare to carry on a new trade or to acquire a trade or trading company. What is reasonably practicable in the circumstances will depend on the facts in each case.

For example, a company may be in negotiations to acquire a trading company but owing to circumstances beyond its control the purchase is delayed. There might be, for example, a problem with the vendor proving title to the company’s assets. In such a case we would not suggest that the acquisition had not been made as soon as was reasonably practicable in the circumstances where this was the reason for the delay.