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HMRC internal manual

Trusts, Settlements and Estates Manual

Trusts for particular purposes: employment related trusts: FURBS - loss of exemption

For the exemption from the rate applicable to trusts/dividend trust rate that was available up to 5 April 2006 to be given, the FURBS must have been established for the sole purpose of providing relevant benefits within the meaning of ICTA/S612.

A FURBS may have been given the exemption from the date of its establishment. But if at any later stage the FURBS provides non-relevant benefits, then it was not ‘established for the sole purpose of providing relevant benefits’. Consequently it loses the exemption for all years when it had been given.