28(1)No agreement for the purposes of, or for purposes connected with giving effect to—
(a)so much of any restructuring scheme as relates to an exempt transaction, or
(b)any exempt transaction to which effect is given by the modification of any restructuring scheme,
shall give rise to a charge to stamp duty reserve tax.
(2)No agreement by which the Treasury or the Secretary of State, or any nominee of the Treasury or the Secretary of State, agrees to transfer securities of a company to another company shall give rise to a charge to stamp duty reserve tax if—
(a)at least one of those companies is a successor company; and
(b)each of the companies is wholly owned by the Crown at the time when the instrument is made.