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HMRC internal manual

Stamp Taxes on Shares Manual

Scope of stamp duty on shares: stamp duty: adjudication, stamps and reliefs: Demutualisation of Insurance Companies

FA97/S96 provides for relief where the whole or part of the business of a mutual insurance company is transferred to a limited company, subject to certain conditions. The relief is intended for transfers under demutualisation schemes where the members of the insurance company become shareholders in the limited company and not schemes where the insurance company is taken over by a third party.

The conditions

  • at least 90 per cent of the members of the insurance company are offered shares in the limited company (or the parent of the limited company)
  • any other shares issued by the limited company go to employees or pensioners of the insurance company or are issued as a result of an offer to the public.

How to claim the relief

Documents for stamping should be sent to Birmingham Stamp Office together with evidence that the conditions of the relief have been met.