CG67826 | Reliefs: employee-ownership trusts: The ‘trustee residence requirement’

Throughout this manual, all legislative references are to Taxation of Chargeable Gains Act 1992 (“TCGA92”) unless otherwise stated.

S236H(4)(za) (inserted by by para 2 of Sch 6 Finance Act 2025) provides that for disposals on or after 30 October 2024, the trustees of the settlement must be resident in the UK,

• at the time of the disposal and

• for the remainder of the tax year in which that time falls.

If there is more than one trustee, the trustees are treated as a single body, see CG10732.