Commentary

I3.156A Dispositions by close companies to employee ownership trusts

IHT, trusts and estates

I3.156A Dispositions by close companies to employee ownership trusts

I3.156A Dispositions by close companies to employee ownership trusts

For dispositions of property made on or after 6 April 2014, a specific relief is introduced in relation to the funding by a close company of an employee ownership trust1. An employee ownership trust is a type of employee benefit trust but the requirements that must be met for a trust to qualify as an employee ownership trust are contained in the capital gains tax legislation.

Under this relief2 no transfer of value arises where a disposition of property is made to trustees by a close company by which the property

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