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SCHEDULES

SCHEDULE 37U.K.Companies owned by employee-ownership trusts

PART 3U.K.Inheritance tax relief

14(1)After section 75 insert—U.K.

75AProperty becoming subject to employee-ownership trust

(1)Tax is not charged under section 65 in respect of shares in or securities of a company (“C”) which cease to be relevant property on becoming held on trusts of the description specified in section 86(1) if the conditions in subsection (2) are satisfied.

(2)The conditions referred to in subsection (1) are—

(a)that C meets the trading requirement,

(b)that the trusts are of a settlement which meets the all-employee benefit requirement, and

(c)that the settlement does not meet the controlling interest requirement immediately before the beginning of the tax year in which the shares or securities cease to be relevant property but does meet it at the end of that year.

(3)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.

(4)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 is treated as having come into force on 6 April 2014.