Commentary

C3.1914 CGT reliefs—disposals on trust for the benefit of employees

Capital gains tax
Capital gains tax | Commentary

C3.1914 CGT reliefs—disposals on trust for the benefit of employees

Capital gains tax | Commentary

CGT reliefs—trusts for the benefit of employees

C3.1914 CGT reliefs—disposals on trust for the benefit of employees

Under IHTA 1984, s 13 there is an exemption from inheritance tax when a close company makes a disposition of property to trustees to be held on trusts for the benefit of all or most of the employees of, or persons holding office with, the company (see I3.156). Exemption is also granted (under IHTA 1984, s 28) to an individual member of the company who disposes of his shares in the company to trustees to be held on trusts in the same way so that, broadly speaking, the trustees then hold all or almost all the ordinary share capital and effectively control the company.

In either case, the trusts must not permit any of the property so settled to be applied, other than as sums taxable in the hands of the recipient, for the benefit of a person who, at any time during the

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