Duty of $50 is chargeable under this Chapter in respect of a transfer of dutiable property that is subject to a trust ( "the principal trust" ) to a beneficiary of the principal trust if –

(a) the beneficiary was a beneficiary when the property, or what was substantially the same property, was first vested in a trustee of the principal trust; and

(b) the transfer is –

(i) to the beneficiary absolutely; or

(ii) to the beneficiary as trustee of another trust ( "the second trust" ) of which all the beneficiaries are natural persons who were beneficiaries of the second trust when the property, or what was substantially the same property, was first vested in a trustee of the principal trust; and

(c) the duty charged by this Act in respect of the first vesting of the property, or what was substantially the same property, in a trustee of the principal trust has been paid.