A disposition of property made to trustees by a close company ("C") whereby the property is to be held on trusts of the description specified in section 86(1) is not a transfer of value if—
C meets the trading requirement,
the trusts are of a settlement which meets the all-employee benefit requirement, and
the settlement does not meet the controlling interest requirement immediately before the beginning of the tax year in which the disposition of property occurs but does meet it at the end of that year.
Sections 236I, 236J, 236K, 236M and 236T (but not 236L) of the 1992 Act apply to determine whether—
C meets the trading requirement;
the settlement meets the all-employee benefit requirement;
the settlement meets the controlling interest requirement;
with references in those sections to "C" being read accordingly.
In this section—
"close company" has the same meaning as in Part 4 of this Act;
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