CG67802 - Reliefs: employee-ownership trusts: statute
Throughout this manual, all legislative references are to Taxation of Chargeable Gains Act 1992 (“TCGA92”) unless otherwise stated.
The relief was introduced through S290 and Schedule 37 Finance Act 2014 (FA14). The rules for relief are in S236H to S236U TCGA92and Sch37, Para 3, FA14 which cover the subjects listed below. The legislation was then amended in Finance Act 2025.
Section 236H Outline of the principal relief
Section 236I The ‘trading requirement’ for C
Section 236J The ‘all-employee benefit requirement’ for the settlement acquiring the shares
Section 236K Provisions about the ‘equality requirement’ in the previous section
Section 236L Cases in which ‘all-employee benefit requirement’ is treated as met
Section 236LA The ‘trustee independence requirement’
Section 236M The ‘controlling interest requirement’ for the settlement acquiring the shares
Section 236N The ‘limited participation requirement’
Section 236O ‘Disqualifying events’ in the tax year following the tax year in which a disposal took place, which prevent the relief from applying
Section 236P ‘Disqualifying events’, which trigger a deemed disposal and reacquisition by the trustees of the settlement
Section 236Q Relief for deemed disposals under TCGA92/S71
Section 236R ‘Disqualifying events’ in the tax year following the tax year in which a deemed disposal under section 236Q took place, which prevent the relief from applying
Section 236S Identification of shares
Section 236T Further provisions about significant and controlling interests
Section 236U Interpretation
Sch 37, Para 3 Transitional provisions, which affect the terms or the application of the following sub-sections of TCGA92
S236H(4)(b), (4)(c)(ii), (5) and (8)
S236N(1) and (3)
S236O
S236P(1), (2) and (3)
S236Q(7)
S236R