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Employee Ownership Trusts - Tax Aspects and Other Issues

The Employee Ownership Trust (EOT) is increasingly becoming seen as a tax-efficient way for an owner to exit the company. Still, there are many conditions to be satisfied and pitfalls to be avoided. Learn how to navigate the rapids without hitting the rocks.

A majestic view of the famous Millennium Bridge in London with people walking across it

A half-day EOT training presented in a virtual class from 9:00am to 1:00pm UK time

EOT Course: A Brief History

  • What is an EOT? The view from 30,000 feet
  • The recent consultation on EOTs and its result, if known
  • What are the potential exit routes for the owner and why might an EOT be appropriate?
    • The qualifying conditions 
    • Trading company or principal company of a trading group 
    • Application to all employees on the “same terms”
    • Acquiring a controlling interest 
    • Shareholders who are directors/employees 
    • Trust property to be applied for the benefit of all eligible employees
  • Employee ownership trusts training explores the 3 steps in creating an EOT:
    • Establishing an EOT and appointing the corporate trustee 
    • Sale of the shares to the EOT 
    • The company make contributions to EOT to pay for the shares
  • Appointing trustees of the EOT
  • Can you sell a partnership business to an EOT?
  • Financing the acquisition for the EOT
  • What are the advantages of selling to an EOT for the original owner?
  • Seeking clearance for transactions in securities from HMRC
  • What are the advantages of an EOT for the employees?
  • Incentivising the employees after the transfer – options and exits
  • Potential areas of concern
  • Potential issues after the transfer for the original owners
  • Disqualifying events after the transfer and their tax consequences

EOT Training Q&A

  • This part of the employee ownership trusts training course allows you to raise examples you have come across and discuss the tax implications
  • Regular pauses for questions on each topic covered to take questions and queries

EOT training is delivered by an expert who advises on all areas of revenue law; both corporate and personal. He has a particular interest in corporate tax matters which include acquisitions and disposals, reconstructions and demergers, MBOs, returning capital to shareholders, s425 schemes, SDLT, stamp duty and SDRT.

He has special expertise in the taxation of insolvent companies, members' voluntary liquidations (including s110 schemes) and bankruptcy. This EOT course trainer lectures regularly to R3 and is a member of the R3/HMRC liaison group which meets regularly to discuss issues of conflict between insolvency law and tax law.

Over the years he has been involved in advising on the tax aspects of some of the UK's major insolvencies including Maxwell, Polly Peck, BCCI, Olympia and York, Mayflower, ITVdigital, MFI, Allied Carpets, Borders, Farepak Lehman Bros. He is a Fellow of the Association of Business Recovery Professionals (FABRP) having passed the JIEB examinations.

Following his call to the bar by Middle Temple in 1986 and pupillage in insolvency chambers (3/4 South Square) where he was a pupil to the late Gabriel Moss QC and tax chambers (Pump Court), he joined Paisner & Co (now Bryan Cave Leighton Paisner) before moving on to Allen & Overy. In 1993 he joined Coopers & Lybrand (now PwC) and Deloitte in 1996, where he was made a corporate tax partner in 1999.

Fearing he would be buried under a pile of budgets, appraisals and forecasts, in 2008 he returned to the Bar and joined Temple Tax Chambers.

  • Identify the different exit routes and why an EOT might provide a suitable exit route for the owners.
  • This employee ownership trusts course will teach you to understand the fundamentals:
    • Setting up an EOT
    • Running an EOT
    • Exiting an EOT
  • Understand the tax advantages for the original owner and those for the employees.
  • Learn what are the potential downsides for both the original owner and the employees.

  • This EOT training combines an examination of the technicalities with the practicalities. It includes examples to assist with understanding the EOT rules.
  • The trainer is a barrister with over 35 years of experience in tax. He has advised on several EOTs often when issues arise.
  • This employee ownership trusts course encourages participation and allows for all questions and clarifications to be considered.
  • We ensure this EOT course is up to date and will include the latest developments including the results of HMRC’s consultation on potential changes.

This EOT course is designed to help attendees appreciate the attractiveness of EOTs as a possible exit route for an entrepreneur. The suitability of this route will be explained when other exit routes may be inappropriate. It will discuss the tax advantages for both the original owners and the employees of the company as well as any potential drawbacks for each. EOT training incorporates the use of examples to apply the rules in practice so that you have a full understanding of the tax consequences for each of the parties involved.
Number of places:

£ 895.00

Discounts available:
Virtual Class

  • 2 places at 30% less
  • 3 places at 40% less
  • 4 places at 50% less
  • 5 places at 55% less
  • 6+ places at 60% less
  • Select the number of course places and dates to automatically calculate the discount
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