The purpose of this Practice Note is to set out an overview of the key capital gains tax (CGT) reliefs and exemptions applicable to business assets which are available to trustees (as well as individual business owners).

This Practice Note examines:

1. •

   CGT reliefs for trustees carrying on a business, namely:

   1. ◦

      business asset roll-over relief

   2. ◦

      incorporation relief

2. •

   CGT reliefs and incentives for trustees as investors, namely:

   1. ◦

      enterprise investment scheme (EIS) and seed enterprise investment scheme (SEIS)

   2. ◦

      relief on company reorganisations

   3. ◦

      relief for losses on loans to traders

EIS and SEIS are an important means of attracting investment into a business. However, this Practice Note focuses on the tax aspects of both schemes as they apply to trustees as investors, ie the EIS income tax and CGT advantages available to an investor.

The reliefs not covered in this Practice Note but for which there are separate Practice Notes are:

1. •

   CGT business asset disposal relief (see Practice Notes: CGT—business asset disposal relief (formerly