Employee benefit trust unit transfers allowed from managers, shareholders and fee conversions, subject to irrevocable gift and subordinate units' ineligibility. Regulation 17I allows an employee benefit trust to receive InvIT units where the investment manager takes management fees in units, shareholders or the investment manager transfer units as irrevocable, gratuitous gifts, and prohibits subordinate units from participation; cash and exercise proceeds held by the trust may be used to acquire units from secondary market or fresh issuances for the employee benefit scheme, and primary market subscriptions are subject to minimum lot rules with narrow exceptions for privately placed unit vesting and off-market odd-lot sales by employees.