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This rollover relief does not apply to disposals on or after 5 April 2001. However, the relief previously given may be withdrawn and a tax charge arise where a chargeable event occurs (see C3.1918) so the rules for the relief are explained here.

For qualifying disposals prior to 5 April 2001¹, and subject to the qualifying conditions described below, a taxpayer could claim rollover relief (QUEST rollover relief)² for gains arising from the disposal of shares to a qualifying employee share ownership trust (generally referred to as a QUEST) where he reinvested the proceeds of the disposal in chargeable assets (see (d) below). The claim had to be made within two years of the acquisition of those replacement assets³.

If the whole of the disposal proceeds were reinvested, the claimant was deemed to have disposed of the shares for a consideration giving rise to no gain/no loss, and the consideration given for the replacement assets was reduced by the excess of the actual disposal