Top 10 Holdings as at 31 October 2004

The Alliance Trust PLC

Top 10 Holdings as at 31 October 2004

Company               Equity       Other       Total     % of
                    Holdings    Holdings     Holding    Gross
                        £000        £000        £000   Assets

BP                    52,683           -      52,683     3.43
Royal Bank of         39,685       8,350      48,035     3.12
Scotland
Shell Transport       47,709           -      47,709     3.10
Glaxo SmithKline      41,430           -      41,430     2.69
Vodafone              34,618           -      34,618     2.25
HBOS                  23,070      10,933      34,003     2.21
Aviva                 16,801       8,444      25,245     1.64
Barclays              21,440           -      21,440     1.39
Rio Tinto             18,637           -      18,637     1.21
Alliance Trust        18,310           -      18,310     1.19
(Finance)*

Total gross assets £1,537,998,313

*  Alliance Trust (Finance) Limited is a subsidiary owned 75% by The Alliance
Trust PLC and 25% by The Second Alliance Trust PLC