The settlement must meet the ‘all employee benefit requirement’ at the time of disposal and for the remainder of the tax year and must not meet the ‘controlling interest requirement’ immediately before the start of the tax year in which the disposal occurs but must meet that requirement at the end of that year. Additionally, if it met the controlling interest requirement at any time in the tax year of the disposal, it must continue to meet it for the remainder of the year (TCGA 1992, s. 236H(4)(b), (c)).

All-employee benefit requirement

The ‘all-employee benefit requirement’ is satisfied if the trusts of the settlement meet the following four conditions:

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