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HMRC internal manual

Stamp Taxes on Shares Manual

Introduction to Stamp Duty on shares and Stamp Duty Reserve Tax (SDRT): SDRT - the liable person: Stamp Duty Reserve Tax - the accountable person

The accountable person is the person responsible for the collection of Stamp Duty Reserve Tax (SDRT) and its prompt payment to HMRC, i.e. the person who has to notify the charge to HMRC and account for, that is pay, the tax. The accountable person is determined by SI1986/1711 Regulation 2.

Where it appears that the appropriate SDRT has not been paid then under the provisions of Regulation 6, HMRC may pursue both the liable person (STSM016010) and the accountable person for payment of the tax.

But if the accountable person can show that he has taken all reasonable steps to recover the tax, but have been unsuccessful (Regulation 7), then HMRC may relieve him of his liability to account and only seek to pursue the liable person for payment of the outstanding tax.