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Taxation of Employee Ownership Trusts and Employee Benefit Trusts

We are seeking views on proposals to reform the tax treatment of Employee Ownership Trusts and Employee Benefit Trusts.

Last fetched 03 May 2026 · gov.uk
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This consultation invites views on proposals to reform the tax treatment of two types of employee trusts: Employee Ownership Trusts and Employee Benefit Trusts.

  • an Employee Benefit Trust (EBT) is a trust set up for the benefit of employees or office holders of a company or group of companies

  • an Employee Ownership Trust (EOT) is a specific type of EBT whereby the trustees own and control the company for the benefit of all of the employees

The aim of the consultation is to ensure that the tax regimes for EBTs and EOTs remain focused on the targeted objectives of rewarding employees and encouraging employee ownership, whilst preventing tax advantages being obtained through use of these trusts outside of these intended purposes.

HMRC welcomes discussions with interested parties. If you would like to meet with policy officials, please contact HMRC.

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