In Henderson Investment Funds v HMRC [2015] UKFTT 505 (16 October 2015) the FTT found that the redemption of units was not exempt from SDRT under FA 1999 Sch 19 para 7.
The issue was the correct amount of SDRT due in respect of the redemption of units held in an equity trust (the ‘fund’) by a pension fund trustee (the ‘unit holder’) in respect of which the unit holder had received a distribution of securities and cash from the fund. It was agreed that the redemption was potentially within the scope of the SDRT charge imposed on a surrender of a unit in a unit trust scheme under FA 1999 Sch 19. The dispute related to the scope of the exclusion from the charge under Sch 19 para 7 which applied ‘if on the surrender of the unit the unit holder receives only such...
