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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Scope of Stamp Duty Reserve Tax (SDRT): conditional and unconditional agreements

Occasionally parties may agree to transfer chargeable securities only on the happening of some future event or on some condition being satisfied.

Under FA86/S87 (2) and (3), the charge to Stamp Duty Reserve Tax (SDRT) arises on the ‘relevant day’ on which the parties to the transaction agree to transfer property. In the case of an unconditional agreement, this is the date the agreement is made. If the agreement is conditional, the relevant day is when all the conditions of the agreement are satisfied or the agreement becomes unconditional.