SCHEDULE 19OPEN-ENDED INVESTMENT COMPANY RELIEFS
Relief from land transaction tax: amalgamation of an authorised unit trust with an open-ended investment company
I12
1
A land transaction transferring any property which is subject to the trusts of an authorised unit trust (“"the target trust””) to an open-ended investment company (“"the acquiring company””) is relieved from tax if the conditions set out in sub-paragraph (2) are met.
2
Those conditions are that—
a
the transfer forms part of an arrangement for the amalgamation of an authorised unit trust with an open-ended investment company, as a result of which the whole of the available property of the target trust becomes part (but not the whole) of the property of the acquiring company,
b
under the arrangement all the units in the target trust are extinguished,
c
the consideration under the arrangement consists of or includes the issue of shares (“"the consideration shares””) in the acquiring company to the persons who held the extinguished units,
d
the consideration shares are issued to those persons in proportion to their holdings of the extinguished units, and
e
the consideration under the arrangement does not include anything else, other than the assumption or discharge by the acquiring company of liabilities of the trustees of the target trust.