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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Reliefs: employee-ownership trusts: conditions: the five 'relief requirements'


This sets out five ‘relief requirements’:

  • the ‘trading requirement’, see [CG67821](,
  • the ‘all-employee benefit requirement’, see [CG67822](,
  • the ‘controlling interest requirement’, see [CG67823](,
  • the ‘limited participation requirement’, see [CG67824](, and
  • the ‘related disposal requirement’, see CG67825.

The first to fourth requirements have to be met in all cases where relief is claimed under either TCGA92/S236H or TCGA92/S236Q.

The fifth requirement is not relevant where there has been a deemed disposal under TCGA92/S71.

More detailed guidance about the five requirements is at CG67830 to CG67856.