IHTM42960 - Employee benefit trusts: dispositions by close companies: dispositions for the benefit of employees

A disposition is not a transfer of value when the terms of IHTA84/S13 are met (IHTM04200). A similar relief for a disposition to an Employee Ownership Trust (IHTM42995) is provided by IHTA84/S13A (IHTM42997)

Where the disposition has been allowable in computing that person바카라 사이트™s profits or gains for the purposes of Income Tax or Corporation Tax and IHTA84/S13(1) is being considered, you should ask the taxpayer or agent for the Inspector바카라 사이트™s reference. You should write to the Inspector asking them to confirm the position. If they confirm the contributions have been allowed then any apparent charge under IHTA84/S13 and IHTA84/S94 automatically falls.

However, this exclusion does not apply where (amongst other things):

  • the contributions by the close company are made to an employee benefit trust (EBT) that does not satisfy IHTA84/S86,
  • the participators (IHTM42955) in the company and any person connected with them are not excluded from benefit under the terms of the EBT so IHTA84/S13(2) applies.