227 Conditions for roll-over relief

Employee share ownership trusts

227  Conditions for roll-over relief

(1)     Relief is available under section 229(1) where each of the 6 conditions set out in subsections (2) to (7) below is fulfilled.

(2)     The first condition is that a person (“the claimant”) makes a disposal of shares, or his interest in shares, to [the trustees of a settlement] which—

(a)     is a qualifying employee share ownership trust at the time of the disposal, and

(b)     was established by a company (“the founding company”) which immediately after the disposal is a trading company or the holding company of a trading group.

(3)     The second condition is that the shares—

(a)     are shares in the founding company,

(b)

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