Subject to certain exceptions1, a charge to stamp duty reserve tax is made where in pursuance of an arrangement:
(1) a person whose business is or includes issuing depositary receipts for chargeable securities2 has issued or is to issue such a depositary receipt3; and
(2) chargeable securities of the same kind and amount are transferred or issued either to the person mentioned in head (1) above, or to a person whose business is or includes holding chargeable securities as nominee or agent for the person who has issued or is to issue the depositary receipt4, or are appropriated by
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