Listed Shares in a Trust: SEBI Perspective

Under the SEBI takeover code, the settlement is itself an acquisition, and the inter se exemption does not reach a trust that has just been created.

This practically leads to two routes: Specific exemption under Regulation 11 complying with the conditions that follow the shares for as long as the trust holds them; or settle the trust now with a nominal holding, disclose it inside the promoter group, and let three years run, so that the block moves later under the general exemption rather than by application.

The carousel below sets out the vehicle, the trigger, the argument and the route.