The idiot socialist who reports business for the BBC as though it is a crime gave us his low down on the Vodafone disposal of its interest in Verizon Wireless.
There would be a substantial capital (true), which would be exempt from UK capital gains tax (true), because the shares in the US company were owned by a Dutch holding company (also true) and therefore outside the scope of UK Capital Gains Tax (no disposal by a UK company) and also exempt from Dutch tax (Peston didn'y go into theis but s called a Participation Exemption), If you really want to know the participation exemption applies where a company holds at least 5% of the nominal paid-up capital of another company and the participation is not held as a portfolio investment or the company is subject to a tax on its profits that is reasonable according to Dutch standards or the aggregated assets of the subsidiary consist for more than 50% of business assets where the profits are taxed at a reasonable tax rate according to Dutch standards.
All bog standard tax planning, but likely to incur the ire of all the tax protesters of the world, particularly those who like camping outside big city churches that are handily placed for Starbucks.
So our joy was unconfined when Pesto came back on the radio at the next business broadcast to repeat the story, only adding this time, that if the disposal had been within the scope of UK Capital Gains Tax it would have been exempt under the Substantial Shareholdings Exemption, an invention of Gordon Brown.
The curious thing about the SSE, which I never really understood, was that according to the Scottish Fool who introduced it, it was supposed to encourage investment, yet rather than giving tax breaks when investments were made, the tax breaks arose when investments were sold, and applied equally to investments tat had already been made prior to the creation of the exemption. Still I am not the leader of a political party that was desperate for contributions from friends in the private equity business, and that's a story for another day.