TSEM3245 - Capital items that are income for tax purposes: chargeable event gains in respect of Employee Share Ownership Trusts
ICTA88/S68(2) and ICTA88/S71(4)
There is a charge to tax on trustees of a qualifying share ownership trust in respect of contributions they received from a company for which relief has been given under FA89/S67. The charge is imposed when a chargeable event occurs and is at the trust rate. There is further guidance at TSEM5525.