CG53190 | Substantial shareholdings exemption: the exemptions available - other cases excluded from exemption
From HM Revenue & Customs · Capital Gains Manual
TCGA92/SCH7AC/PARA6
Paragraph 6 Schedule 7AC TCGA 1992 provides that three cases are excluded from the substantial shareholdings exemption regime. None of the exemptions is available
where the disposal is deemed to be for a consideration such that no gain or loss accrues to the person making the disposal;
where a gain on the disposal would not be a chargeable gain by virtue of any other enactment;
Paragraph 6 also specifically provides that the hypothetical disposals contemplated by
are to be assumed not to be disposals which paragraph 6 excludes from the exemptions.