CG53205 - Substantial shareholdings exemption: interaction with other legislation - meaning of chargeable shares and chargeable assets
TCGA92/SCH7AC/PARA32
Paragraph 32 Schedule 7AC TCGA 1992 provides that exemptions conferred by the substantial shareholding exemption regime do not prevent shares or assets being 鈥榗hargeable shares鈥� or 鈥榗hargeable assets鈥� 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 鈥榗hargeable gains鈥�. However, there is no intention that this should change the way any legislation that relies on distinguishing chargeable assets or shares operates.