SCHEDULES

SCHEDULE 37Companies owned by employee-ownership trusts

PART 3Inheritance tax relief

11(1)After section 28 insert—

28AEmployee-ownership trusts

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

(a)C meets the trading requirement,

(b)the settlement meets the all-employee benefit requirement, and

(c)the settlement does not meet the controlling interest requirement immediately before the beginning of the tax year in which the transfer of value is made but does meet it at the end of that year.

(2)Sections 236I, 236J, 236K, 236M and 236T (but not 236L) of the 1992 Act apply to determine whether—

(a)C meets the trading requirement;

(b)the settlement meets the all-employee benefit requirement;

(c)the settlement meets the controlling interest requirement;

with references in those sections to “C” being read accordingly.

(3)In this section “tax year” means a year beginning on 6 April and ending on the following 5 April.

(2)The amendment made by this paragraph has effect in relation to transfers of value made on or after 6 April 2014.