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HMRC internal manual

Stamp Taxes on Shares Manual

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HM Revenue & Customs
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Exemptions and Reliefs: Exemptions: Authorised unit trust scheme (and OEIC) mergers

HMRC’s SDRT Customer Newsletter Issue No. 7 relates to the amalgamations and mergers of unit trusts and OEICs. It can be found at http://webarchive.nationalarchives.gov.uk/20141128071155/http://www.hmrc.gov.uk/so/sdlt_news7.htm

The Newsletter was issued in the wake of Save & Prosper Securities Ltd v. CIR (Sp.C 251). In this case, two Authorised Unit Trust schemes (AUTs) amalgamated by way of a scheme of arrangement which took effect by operation of law.

Following this case, HMRC accepts that no Stamp Duty Reserve Tax (SDRT) charge will arise where certain transactions are effected by a similar scheme of arrangement. These transactions include: amalgamation of AUTs or sub-funds of AUTs; partition of an AUT into another AUT or sub-fund; similar transactions involving open-ended investment companies (OEICs); and certain reconstructions of AUTs or OEICs. Full details are in the Newsletter.