2(1)There is a charge to stamp duty reserve tax where—
(a)a person authorises or requires the trustees or managers under a unit trust scheme to treat him as no longer interested in a unit under the scheme, or
(b)a unit under a unit trust scheme is transferred to the managers of the scheme,
and the unit is a chargeable security.
Those events are referred to in this Part of this Schedule as a “surrender” of the unit to the managers.
(2)The tax is chargeable—
(a)whether the surrender is made or effected in the United Kingdom or elsewhere, and
(b)whether or not any party is resident or situate in any part of the United Kingdom.
(3)The persons liable for the tax are the trustees of the unit trust.
(4)This paragraph is subject to the exclusions provided for in paragraphs 6 and 7.