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HMRC internal manual

Stamp Taxes on Shares Manual

Scope of Stamp Duty Reserve Tax (SDRT): chargeable securities - general

The principal charge to Stamp Duty Reserve Tax (SDRT) applies where there is an agreement to transfer chargeable securities.

‘Chargeable securities’, as defined in FA86/S99, include:

  • stocks, shares or loan capital
  • interests in, or in dividends or other rights arising out of securities
  • options to acquire and rights to allotment of or to subscribe for securities
  • units under a unit trust scheme

‘Chargeable securities’ as defined in FA1986/S99 do not include:

  • securities which are exempt from all stamp duties
  • securities which relate to underlying securities which are exempt, such as gilts and non-convertible loan capital
  • loan capital where the return bears an inverse relationship to results
  • interests in depositary receipts for stocks or shares, which will instead be subject to the 1.5 per cent charge
  • securities which:

    • are issued or raised by a company incorporated outside the UK (and with no UK register)
    • are not paired with shares in a UK company (FA86/S99 (4))
    • are issued or raised by a Societas Europaea (SE) with a registered office outside the UK (FA86/S99 (4A))
  • units in a non-UK or exempt trust.