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HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: interaction with other legislation - meaning of chargeable shares and chargeable assets


Paragraph 32 Schedule 7AC TCGA 1992 provides that exemptions conferred by the substantial shareholding exemption regime do not prevent shares or assets being ‘chargeable shares’ or ‘chargeable assets’ for tax purposes.

The Taxes Acts often distinguish a chargeable asset or share form other assets or shares for various purposes by reference to whether a chargeable gain would accrue on a disposal. For instance, in the Corporate Venturing Scheme at paragraph 13 Schedule 15 Finance Act 2000 and in the special rules for the disposal of shares within a prescribed period at section 106(10) TCGA 1992.

The exemption regime provides that certain gains are not ‘chargeable gains’. However, there is no intention that this should change the way any legislation that relies on distinguishing chargeable assets or shares operates.