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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Reliefs: employee-ownership trusts: transitional provisions

The rules governing the relief are slightly different for disposals that took place on or after 6 April 2014 but before 26 June 2014. This is because some significant amendments to the legislation as originally published were not published until the latter date. The points below summarise the differences and refer to the guidance which applies where relief is claimed in connection with disposals during this period.

CG67822                      The settlement has to meet the ‘all-employee benefit requirement’ at the time of the disposal but not for the remainder of the year in which it took place, that is the year ended 5 April 2015.

CG67823                      The settlement has to meet the ‘controlling interest requirement’ only at the end of the tax year in which the disposal took place, that is at 5 April 2015.

CG67855                      The value of the ‘participator fraction’ during the period beginning with the disposal and ending at the end of the tax year in which the disposal took place is not relevant in determining if the ‘limited participation requirement’ is met.

CG67860                      The special rules regarding ‘disqualifying events’ in the tax year next following a disposal by P of shares in C do not apply.

CG67861                      Instead of the rules at CG67860 applying, CG67861 describes the consequences of a ‘disqualifying event’ during the year of disposal.

CG67866                      The rules specifying the consequences of a ‘disqualifying event’ in the tax year next following a deemed disposal by trustees under TCGA92/S71 do not apply. There are no special, alternative rules analogous to those at [CG67861](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg67861), which apply in these circumstances.