Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section Schedule 19 paragraph 2

Relief for amalgamation of authorised unit trust with open-ended investment company

Schedule 19 paragraph 2 provides relief from land transaction tax when property is transferred from an authorised unit trust to an open-ended investment company as part of an amalgamation, provided certain conditions are met.

• A land transaction transferring property from an authorised unit trust (the target trust) to an open-ended investment company (the acquiring company) can be relieved from LTT if specific conditions are satisfied.
• The transfer must be part of an amalgamation arrangement where all the target trust's available property becomes part (but not the whole) of the acquiring company's property, and all units in the target trust are extinguished.
• The consideration for the transfer must consist of, or include, shares issued by the acquiring company to the former unit holders, allocated in proportion to their original holdings.
• No other consideration may be provided apart from the shares and the acquiring company assuming or discharging liabilities of the target trust's trustees.