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HMRC internal manual

Stamp Taxes on Shares Manual

Scope of stamp duty on shares: stamp duty: adjudication, stamps and reliefs: mergers of AUTs

The transfer of property as a consequence of the merger of Authorised Unit Trusts (AUTs) is, subject to certain conditions, relieved from Stamp Duty by the provisions of FA97/S95.

The conditions

  • the transfer forms part of an arrangement under which the whole of the available property of the target trust is transferred to the trustees of the acquiring trust
  • all the units in the target trust are extinguished
  • the consideration consists of or includes the issue of units in the acquiring trust to the persons who held the extinguished units
  • the units are issued to those persons in the same proportion as their extinguished units
  • there is no other consideration apart from the assumption or discharge of liabilities of the trustees of the target trust by the trustees of the acquiring trust

How to claim the relief

Documents for stamping should be sent to Birmingham Stamp Office together with evidence that the conditions of the relief have been met.