Summary 
 
Beneficiaries were not required to have been ‘qualifying beneficiaries’ of their settlements throughout the period of one year ending not earlier than three years before disposals of trust assets. 
 
Background 
 
On 30 July 2015, three beneficiaries were each given an interest in possession in a settlement in their own names, in the whole of the settled property. On 11 August 2015, by three separate deeds of gift, the settlor gave ‘D’ ordinary shares in a company to each of the three settlements. The beneficiaries had each held ‘C’ class shares granting full voting rights since 2011 and were officers of the company. As such, the company was a ‘personal company’ of each of them (for entrepreneurs’ relief purposes, under TCGA 1992, s 169S). 
 
On 1 December 2015,