CG67820 - Reliefs: employee-ownership trusts: conditions: the eight 'relief requirements'

Throughout this manual, all legislative references are to (“TCGA92�) unless otherwise stated.

TCGA92/S236H(4)

This sets out eight ‘relief requirements�:

  • the ‘trustee residence requirementâ€�, see CG67826,
  • the ‘trading requirementâ€�, see CG67821
  • the ‘all-employee benefit requirementâ€�, see CG67822
  • the ‘trustee independence requirementâ€�, see CG67827,
  • the ‘controlling interest requirementâ€�, see CG67823
  • the ‘consideration requirementâ€� see CG67828,
  • the ‘limited participation requirementâ€�, see CG67824Ìý²¹²Ô»å
  • the ‘related disposal requirementâ€�, see CG67825.

»Ê¹ÚÌåÓýapp first to fifth and the seventh requirements have to be met in all cases where relief is claimed under either S236H or S236Q.

»Ê¹ÚÌåÓýapp sixth and eighth requirements are not relevant where there has been a deemed disposal under S71.

»Ê¹ÚÌåÓýapp ‘trustee residence requirementâ€�, ‘trustee independence requirementâ€� and ‘consideration requirementâ€� only apply to disposals made on or after 30 October 2024.

More detailed guidance about the other five requirements is at °ä³Ò67830Ìý³Ù´ÇÌýCG67856.