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Any rollover relief given under TCGA 1992, s 229 (for disposals made before 6 April 2001; see C3.1917) may be withdrawn if a chargeable event occurs after the date of the disposal of the shares to the share ownership trust.

The relief given may be recovered where the claimant (or a person connected with him) still owns beneficially any of the replacement assets acquired on the disposal of the shares¹, or where gains accruing on the disposal of those assets have been rolled over into replacement business assets². However, the relief will not be withdrawn if the claimant was an individual who died before the chargeable event occurs or the trustees of a settlement which ceased to exist before the chargeable event occurs³.

Except where the replacement assets are shares which have been exchanged for qualifying corporate bonds, the provisions for recovering relief do not take account of any fall in value in the replacement assets.