Related Commentary  Related CasesRelated HMRC Manuals

28(1)  A transfer of value made by an individual who is beneficially entitled to shares in a company is an exempt transfer to the extent that the value transferred is attributable to shares in or securities of the company which become comprised in a settlement if–

(a)the trusts of the settlement are of the description specified in section 86(1) below, and

(b)the persons for whose benefit the trusts permit the settled property to be applied include all or most of the persons employed by or holding office with the company.

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