STAMP DUTY RESERVE TAX– surrender of units in unit trust scheme – redemption in specie-relief where unit holder receives a proportionate share of all the trust assets-whether relief applies if and only if the unit holder receives a proportionate share of all the trust assets (as nearly as practicable) or to the extent that the unit holder receives such a share-paragraphs 2 and 7 Schedule 19 Finance Act 1999.

Richard Vallat, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents.

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