Course Details

Selling a company to an employee ownership trust can mean that the vendors do not pay any capital gains, regardless of the size of the gain! Conditions for this relief are quite complex and there are a number of traps that can catch the unwary. On the other hand, the tax prize is clearly worth discussing with clients. In this session we aim to cover the basic requirements to qualify for the relief, along with a number of practical difficulties that we have run across in live cases.


This session will be useful for anyone advising clients on the sale of their trading company. This is an important relief and one which all clients should be made aware of, even if, in the final analysis, it is not commercially the right answer.


In this session, Pete Miller & Nick Wright cover the following topics:

  • Scope of the reliefs
  • Relief requirements
  • Disqualifying events
  • Clearances
  • Pitfalls

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CPD Course Speaker

The Miller Partnership

Pete Miller

Pete formed The Miller Partnership in April 2011 to offer expert advice to other advisers on all business and corporate tax issues. Pete’s specialist areas include the transactions in securities rules, reorganisations, reconstructions, distributions, partnerships, Patent Box, HMRC clearances, disguised remuneration and the taxation of intangible assets.

Pete has worked in tax for over 33 years, including nearly 10 years as an Inspector of Taxes. He worked in Birmingham and London with roles in both Policy and Technical Divisions, where he was the Inland Revenue’s expert on all matters relating to the distributions legislation. He then worked for 11 years in ‘Big 4’ firms, specialising in the taxation of corporate transactions.

Pete speaks and writes regularly on tax issues and is lead author of Taxation of Company Reorganisations (Bloomsbury Professional, 6th Edition October 2020).

Jerroms Miller

Nick Wright

Associate director Nick joined Jerroms as a Corporate Tax Manager in 2019 to undertake technical tax research, planning and advisory projects for business and corporate clients.

With Pete and the team, he provides specialist corporate tax advice in areas such as transactions tax, company reconstructions and Employee Ownership Trusts, Employment Related Securities and employee share schemes both to individuals and to accountants and solicitors requiring support for their own clients.

Nick particularly enjoys finding solutions to planning projects in often very technical/complex taxation areas, as well as supporting clients to achieve the optimum solution to their business tax issue, whether that relates to selling their business, demerging, or rewarding employees.