The SSE was first conceived as a form of rollover relief. Rollover relief is limited to assets used for the purposes of a trade. Business successfully lobbied in favour of an exemption rather than rollover but was unsuccessful in removing the trading requirements, the government of the day stating that “the restriction of the relief to trading companies and groups is most likely to bring about a use of the proceeds which will contribute to productivity gains”.
This restriction, coupled with the absence of a legislative definition of trading activities and the requirement to test the worldwide group, is responsible for many of the complexities and uncertainties which render the SSE uncompetitive in comparison with regimes in other holding company locations.
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