s 33 Directions as to disposal of shares in certain circumstances
33.—(1) Subject to subsection (2), where a disposal of shares in a company by a transferor to a transferee is effected by —(a) the cancellation of the shares of the transferor in the company; and (b) the issue of new shares in that company to the transferee, such disposal of shares is treated as a transfer of shares from the transferor directly to the transferee and ad valorem duty is chargeable on any instrument that, in the Commissioner’s opinion, effects, whether directly or indirectly and whether wholly or partially, any arrangement for the disposal of the shares. [35/2014] (2) Subsection (1) does not apply to a disposal of shares made for the purpose of effecting an amalgamation of companies under section 215D of the Companies Act 1967.[35/2014]