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United KingdomGOV.UK

HMRC confirms EU exit-charge rebasing preserves the SSE holding period

A company migrating to the UK under section 184J can retain its shareholding history: market-value acquisition treatment does not trigger the deemed-disposal reset.

By Taxxa AI OyPublished 19 August 2026

Tax

HMRC has clarified that a company’s substantial-shareholding holding period is unaffected when it migrates to the UK, becomes subject to an EU exit charge and receives market-value acquisition treatment under section 184J. The clarification concerns the holding-period test for the substantial shareholdings exemption (SSE), rather than treating migration as a fresh start for that test.

Section 184J applies where an asset becomes chargeable to corporation tax because the company becomes UK resident and the company becomes subject to an EU exit charge on that event in relation to the asset. It treats the company as having acquired the asset for its market value when it became chargeableLegislation. A chargeable asset is one whose disposal gain would be chargeable to corporation tax.

The section also covers a non-UK-resident company whose asset begins to be held for a trade carried on through a UK permanent establishment, subject to the same chargeable-asset and EU-exit-charge conditions. The statutory definition of an EU exit charge is a tax charge under a member state’s law in accordance with Article 5(1) of Directive (EU) 2016/1164. HMRC’s added explanation specifically addresses migration to the UK.

The distinction matters because paragraph 11 of Schedule 7AC ordinarily interrupts the holding period following a deemed disposal and reacquisition of the shares or interest concerned, or the shares or interest from which they deriveGOV. It defines this as a disposal and immediate reacquisition treated as taking place under corporation-tax legislation. HMRC explains that section 184J does not provide for that paired deemed disposal and reacquisitionGOV. Its market-value acquisition treatment therefore does not, by itself, reset the holding period in the migration case describedGOV.

The underlying duration requirement remains a substantial shareholding held throughout a twelve-month period beginning no more than six years before disposal. HMRC’s clarification allows the existing holding history to remain relevant when applying that requirement. It addresses continuity of ownership for the test; the company must still satisfy the substantial-shareholding requirement for the relevant period.

HMRC’s clarification concerns section 184J and Schedule 7AC, paragraph 11, of the Taxation of Chargeable Gains Act 1992.

Review the SSE holding-period calculation for companies migrating to the UK under section 184J, retaining the pre-migration holding history where HMRC’s stated conditions apply.

Sources