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HMRC internal manual

Stamp Taxes on Shares Manual

From
HM Revenue & Customs
Updated
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Scope of Stamp Duty Reserve Tax (SDRT): territorial scope

FA96 clarified and extended the territorial scope of Stamp Duty Reserve Tax (SDRT) so that it is chargeable:

  • whether or not the agreement to transfer chargeable securities is made in the UK and
  • whether or not any party to the transaction is UK resident ( FA86/S86 (4)).

Chargeable securities are, broadly,

  • securities issued or raised by UK incorporated companies
  • securities issued or raised by foreign companies that maintain a UK register
  • securities issued or raised by a Societas Europaea (SE) with its registered office in the UK
  • shares in foreign companies which are ‘paired’ with UK shares, and
  • interests and rights arising out of the above shares and securities (within FA86/S99 (3)(b) and (c)).

For further details on chargeable securities, see STSM031090.