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HMRC internal manual

Stamp Taxes on Shares Manual

Exemptions and reliefs: exemptions: loan capital exemption - miscellaneous

Other Specific Loan Capital Exemptions

Transfers of loan capital issued by the following are also exempt from stamp duty under separate legislation:

  • The International Bank of Reconstruction and Development
  • The EEC
  • The European Coal and Steel Community
  • The European Atomic Energy Authority
  • The European Investment Bank

Convertible Notes

Transfers of Convertible Notes are liable to stamp duty. Sometimes building societies have or issue Convertible Notes which automatically convert into Permanent Interest Bearing Shares (PIBS) within a few months. The Notes are loan capital but the conversion rights attached to them deny the exemption applicable to the transfer of loan capital by virtue of Section 79(5) Finance Act 1986. These transfers should not be confused with the transfers of PIBS which are exempt. (See STSM021230, STSM021240 and STSM041100).