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HMRC internal manual

Stamp Taxes on Shares Manual

Introduction to Stamp Duty on shares and Stamp Duty Reserve Tax (SDRT): Stamp duty rates: Stamp Duty - transfers to clearance services and depositary receipt Issuers

The 1.5% rate of duty is imposed on instruments transferring relevant securities in a UK company to a clearance service by virtue of FA86/S70. Where the instrument represents a transfer of securities on sale, the 1.5% charge is calculated by reference to the amount or value of the consideration paid (FA86/S70(2)). Where an instrument represents a transfer of securities otherwise than on sale, the 1.5% charge is calculated by reference to the value of the securites at the date the instrument is executed (FA86/S67(3)).

Further information is at STSM052020.

The 1.5% rate of duty is imposed on instruments transferring relevant securities in a UK company to a depositary receipt issuer by virtue of FA86/S67. Section 67(2) imposes the charge on the consideration if the instrument is a conveyance on sale within the meaning of FA99/SCH13/PART1. In any other case Section 67(3) imposes the charge on the instrument by reference to the value of the securities.

Further information is at STSM051030.

Where an instrument transferring securities in a UK company is exected pursuant to the exercise of an option to buy or sell the securities and the transfer is to a clearance service or depositary receipt issuer (or to their respective nominees), a 1.5% charge is calculated by reference to (a) the amount or value of the consideration paid for the sale or (b) the value of the UK securities at the date the transfer instrumrnt id executed, whichever is the higher.

In all of the above cases the rounding provisions of FA99/S112(1) apply. See STSM013040.