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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Introduction to Stamp Duty on shares and Stamp Duty Reserve Tax (SDRT): Stamp duty and SDRT basics: certificate of value

In all cases where the rate of duty charged is dependent on the amount of the chargeable consideration, the appropriate certificate of value must be incorporated in the document to allow that document to benefit from any particular rate. Uncertified documents attract duty at the highest rate applicable to that type of transaction by reference to the rates of duty in force at the date of execution.

In order to reduce the administrative burden of complying with Stamp Duty legislation, changes were made to primary legislation in FA08 to remove the requirement for a £5 duty stamp except where the instrument was part of a larger transaction or series of transactions involving further instruments transferring interests in stock or marketable securities.

A certificate within the meaning of FA99/Sch13/Para6(1) for a transfer of stock or marketable security should read “It is hereby certified that the transaction effected by this instrument does not form part of a larger transaction or series of transactions in respect of which the amount or value, or aggregate amount or value, of the consideration exceeds £1,000.” A document which would otherwise benefit from the nil rate of ad valorem duty cannot do so unless it contains that certificate.