This Practice Note examines some of the key tax and practical considerations that arise when a company owned by an employee ownership trust (EOT) is sold out of the EOT. These issues include the need for the trustees to consider whether the sale is in the best interests of beneficiaries, taking account of any capital gains tax (CGT) for which the trustees may be liable and any debts owed to the parties from whom the EOT originally acquired the company, potential difficulties in identifying and tracing all of the EOT beneficiaries who may be entitled to the surplus sale proceeds, and the operation of PAYE and NICs in respect of distributions to those beneficiaries.