EOT decision guide
For qualifying disposals from 26 November 2025, 50% of the gain is chargeable now and 50% is held over against the trustees' acquisition cost.
For a qualifying disposal to an Employee Ownership Trust on or after 26 November 2025, 50% of the gain is treated as the seller's chargeable gain. The other 50% is relieved at that point, but it is deferred rather than eliminated.
The held-over 50% is deducted from the trustees' acquisition cost (their base cost). It can therefore come back into charge on a later disposal or deemed disposal of the shares by the trustees.
Business Asset Disposal Relief and Investors' Relief cannot be claimed on a disposal where EOT relief is claimed. They are therefore unavailable against the 50% gain charged to the seller.