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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Scope of stamp duty on shares: stamp duty: basics of a charge: reliefs

The more common reliefs applying to transactions within the stamp duty regime include:

  • Intra-group relief - reduces duty to nil for transfers between associated companies provided that certain conditions are met (FA30/S42). See STSM022110 
  • Acquisition relief (whole of target company’s share capital) - reduces duty to nil when certain conditions are met (FA86/S77). See STSM022130 
  • Transfer of all or part of a company’s undertaking - reduces duty to nil when certain conditions are met (FA86/S75). See STSM022120 
  • Sales to Intermediaries - no duty payable on transfers of stock to recognised intermediaries (FA86/S80A0. See STSM022210 
  • Repurchases and Stock Lending - no duty on transfers of stock meeting certain criteria (FA86/S80C). See STSM022240 
  • Transfers to charities - no duty payable when certain criteria are met (FA82/S129). See STSM022140 
  • Loan capital - usually exempt subject to certain exceptions (FA86/S79). See STSM021220.

A full list of reliefs currently available which require formal adjudication can be found in the section dealing with adjudication. See STSM022100.