Top 10 Holdings as at 31 October 2005

The Alliance Trust PLC

In accordance with paragraph 20.21(l)(ii) of the Listing Rules, The Alliance Trust
PLC declares that its ten largest investments, including all holdings with a
value greater than 5% of its gross assets, as at 31 October 2005 were:

Company                                           Equity      Fixed Income  Total Holdings   % of  Gross
                                                Holdings    Holdings £000s           £000s        Assets
                                                   £000s
BP PLC                                            69,411                            69,411          3.86
ROYAL DUTCH SHELL                                 58,926                            58,926          3.28
GLAXOSMITHKLINE PLC                               58,171                            58,171          3.24
VODAFONE GROUP PLC                                40,347                            40,347          2.25
HBOS PLC                                          32,060             7,824          39,885          2.22
RIO TINTO PLC ORD 10P                             31,906                            31,906          1.78
ALLIANCE TRUST SAVINGS                            25,720                            25,720          1.43
ROYAL BANK OF SCOTLAND                            25,240                            25,240          1.41
BARCLAYS PLC ORD 25P                              24,592                            24,592          1.37
HSBC HOLDINGS PLC ORD $0.50                       23,849                            23,849          1.33

Total Gross Assets (£000s) £1,796,389


Name of contact                              Mr Ian Goddard

Telephone Number                             01382 201700

Date of notification                         2 November 2005