Paragraph 7.7 of this guide requires that where an umbrella VCC effects an acquisition or disposal between the VCC and its sub-funds, or between sub-funds, without a formal dutiable instrument, a notice under section 60I or 60J of the Stamp Duties Act must be lodged with the Commissioner of Stamp Duties within 14 days. Non-compliance constitutes a criminal offence carrying a fine of up to four times the applicable stamp duty. Compliance functions at VCC management entities will need to maintain transaction monitoring covering intra-structure asset movements not evidenced by formal instruments.