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HMRC internal manual

Trusts, Settlements and Estates Manual

Capital items that are income for tax purposes: chargeable event gains in respect of Employee Share Ownership Trusts

ICTA88/S68(2) and ICTA88/S71(4)

There is a charge to tax on trustees of a qualifying share ownership trust in respect of contributions they received from a company for which relief has been given under FA89/S67. The charge is imposed when a chargeable event occurs and is at the trust rate. There is further guidance at TSEM5525.