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Autumn Budget 2024: EOTs - changes in Finance Bill

Although not mentioned in the Budget speech the accompanying documents included a policy paper and draft legislation proposing changes to the EOTs regime. Most of these changes will have an effect for disposals to an employee ownership trust on or after 30 October 2024. The announcement was a bit of a surprise in the sense that there has been a deafening silence on the subject from HMRC since the consultation finished over a year ago. Given the change of government and the likely priorities of the new administration we were not expecting anything on EOTs in the current budget.

The changes that have been announced largely appear to follow the script of the original consultation document and do not appear to take into account many of the comments made in response to that consultation.

The changes are:

  • The trustees of a settlement must be UK resident. If the trustees cease...

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