SCHEDULES

SCHEDULE 4 Taxation Provisions

Part II Stamp Duty and Stamp Duty Reserve Tax

Stamp duty reserve tax

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.