Article 72 - Participation Exemption on Investment in Shares
(1) Subject to Article 73, the gain arising on the disposal of a qualifying shareholding shall be exempt from tax, and any loss arising on the disposal shall not be available for relief under Part 5.
QFC Entity holds a "qualifying shareholding" in a Company if it meets the following conditions—
(a) it holds an interest of at least 10% of the
Ordinary Share Capital of the Company;
(b) it, or another
Company or LLP in the same Group, has held the interest mentioned in Article 72(2)(a) for a continuous period of at least 6 months immediately preceding the date of disposal; and
(c) the shares in the
Company have not been held wholly or mainly with a view to resale.
|Amended (as from 18th June 2014)|