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More highlights from the London Tax Network Tax Conference 2023

Meeting points – 2

Employee ownership trusts

Following on from Sam Wightman’s introduction to employee ownership trusts (EOTs) Pete Miller continued the session by explaining the relief conditions. The all employee benefit requirement means that the trust property (the company) can only be applied for the benefit of ‘eligible employees’ and on the same terms (the ‘equality requirement’). So specific persons must be excluded from the EOT:

  • Any participator of the company or of any group company – those holding more than 5% of the share capital or 5% of any class of share capital of the company. Generally this will be the vendor shareholders.
  • Any participator in another close company that has made a disposition into the same trust that would have been a transfer of value for inheritance tax purposes.
  • Any person who has been such a participator since the trust was first settled.
  • Any person connected...

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