GOV.UK
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.