Relief from land transaction tax: conversion of an authorised unit trust to an open-ended investment company
402.Paragraph 1 of this Schedule outlines the conditions under which relief from LTT may be claimed where there is a land transaction transferring property subject to the trusts of an authorised unit trust to an open-ended investment company. The conditions provide that relief is restricted to those cases where:
the authorised unit trust is converted into an open-ended investment company; and the whole of the property available is transferred and becomes the whole of the property of the open-ended investment company;
as part of the transaction all the units in the authorised unit trust are extinguished;
the consideration under the arrangements consists of or includes the issue of shares in the open-ended investment company to the persons who held the extinguished units;
the shares are issued in the same proportion as the extinguished units held; and
the consideration only comprises the assumption or discharge of liabilities of the trustees of the authorised unit trust.
