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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Employee share schemes: trustees: introduction

Companies that set up an approved Share Incentive Plan (SIP), see CG56490+, have to establish a trust to operate the scheme. The Capital Gains Tax liability of the trustees is covered by special rules in these cases.

Trusts may also be set up in connection with other schemes, where the special SIP rules would not apply. CG56523-CG56530 outline the Capital Gains Tax consequences of arrangements, other than Share Incentive Plans, where shares or other securities are transferred, or options granted, to employees by employee trusts.

For further information on employment-related trusts that may be set up by employers see TSEM5005+.