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HMRC internal manual

Stamp Taxes on Shares Manual

Scope of stamp duty on shares: stamp duty: adjudication, stamps and reliefs: Formal Notice of Decision on Adjudication

A Formal Notice of Decision on Adjudication is prepared in a particular format and is traditionally drafted by the Solicitors’ Office within HMRC. It is an essential prerequisite for any formal appeal against the duty calculation or imposition of a penalty.

It will clearly identify the document or documents in question, state the Commissioners’ opinion of the duty, together with any interest and penalty, that is payable and state the legislation under which the charge(s) arise.

If the document is not stamped in accordance with the Formal Notice of Decision on Adjudication within 30 days after the date of the notice, the person who requested the adjudication is liable to a penalty not exceeding £300 under the provisions of Section 12A(2) Stamp Act 1891.