Beneficiaries were 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 for entrepreneurs’ relief purposes. 

Summary 

Beneficiaries were 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 for entrepreneurs’ relief purposes. 

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