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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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HM Revenue & Customs
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Schedule 4 Company Share Option Plan (CSOP): Eligibility of individuals to participate: The "no material interest" requirement: Beneficiaries of Employment Benefit Trusts

The employee benefit trusts to which paragraph 13 applies are those which satisfy the following conditions set out in sections 550 and 551 of Chapter 10 Part 7:

  1. all or most of the employees of the company are eligible to benefit under it, and
  2. none of the money or ordinary shares held in the trust has been disposed of (whether by sale, loan or otherwise) on or after 14 March 1989, other than:
  • in the ordinary course of management of the trust,
  • by being applied for the benefit of employees and ex- employees of the company and their relatives,
  • by being applied for charitable purposes,
  • by being transferred to the trustees of an another EBT, qualifying employee share ownership trust (QUEST) or a profit sharing scheme.