CG67880 - Reliefs: employee-ownership trusts: transitional provisions

»Ê¹ÚÌåÓýapp rules governing the relief are slightly different for disposals that took place on or after 6 April 2014 but before 26 June 2014. This is because some significant amendments to the legislation as originally published were not published until the latter date. »Ê¹ÚÌåÓýapp points below summarise the differences and refer to the guidance which applies where relief is claimed in connection with disposals during this period.

CG67822 »Ê¹ÚÌåÓýapp settlement has to meet the ‘all-employee benefit requirementâ€� at the time of the disposal but not for the remainder of the year in which it took place, that is the year ended 5 April 2015.

CG67823 »Ê¹ÚÌåÓýapp settlement has to meet the ‘controlling interest requirementâ€� only at the end of the tax year in which the disposal took place, that is at 5 April 2015.

CG67855 »Ê¹ÚÌåÓýapp value of the ‘participator fractionâ€� during the period beginning with the disposal and ending at the end of the tax year in which the disposal took place is not relevant in determining if the ‘limited participation requirementâ€� is met.

CG67860 »Ê¹ÚÌåÓýapp special rules regarding ‘disqualifying eventsâ€� in the tax year next following a disposal by P of shares in C do not apply.

CG67861 Instead of the rules at CG67860 applying, CG67861 describes the consequences of a ‘disqualifying event� during the year of disposal.

CG67866 »Ê¹ÚÌåÓýapp rules specifying the consequences of a ‘disqualifying eventâ€� in the tax year next following a deemed disposal by trustees under TCGA92/S71 do not apply. »Ê¹ÚÌåÓýappre are no special, alternative rules analogous to those at CG67861, which apply in these circumstances.