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HMRC internal manual

Trusts, Settlements and Estates Manual

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

When a FURBS set up before 6 April 2006 is wound up, benefits may be provided in the winding up which fall within the definition of non-relevant benefits. If non-relevant benefits are provided in the winding up, the FURBS loses its exemption from the rate applicable to trusts/dividend trust rate for all years up to April 2006 (TSEM5357).

What happens depends on the definition of non-relevant benefits that applies at the point in time when the benefits are provided. The definitions are in ICTA/S612 and ITEPA/S393B.

If you need advice on the application of ICTA/S612 or ITEPA/S393B, contact Pension Scheme Services (Technical), Fitz Roy House, Castle Meadow Road, Nottingham NG2 1BD.

TSEM5359 gives examples of what can happen to the exemption when a FURBS winds up.