12(1)No agreement made for the purposes of or for purposes connected with a transfer scheme shall give rise to a charge to stamp duty reserve tax.E+W+S
(2)No agreement which is made in pursuance of Schedule 10 to this Act shall give rise to a charge to stamp duty reserve tax.
(3)No agreement by which the Treasury or the Secretary of State, or any nominee of the Treasury or 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)either or both of the companies are successor companies; and
(b)each of the companies is, at the time when the agreement is made,
wholly owned by the Crown.