Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 19 paragraph 1

Relief for conversion of authorised unit trust to open-ended investment company

Schedule 19, paragraph 1 provides land transaction tax relief when property is transferred from an authorised unit trust to an open-ended investment company as part of a formal conversion arrangement, provided certain conditions are met.

• When an authorised unit trust converts into an open-ended investment company and land is transferred as part of that conversion, the transfer may be relieved from land transaction tax.
• The relief requires that all the property of the unit trust becomes all the property of the new company, and all units in the trust are extinguished.
• The former unitholders must receive shares in the new company in proportion to the units they held, and these shares must form the consideration for the arrangement.
• No other consideration may be provided apart from the shares and the new company assuming or discharging liabilities of the trust's trustees.