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HMRC internal manual

Stamp Taxes on Shares Manual

From
HM Revenue & Customs
Updated
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Exemptions and Reliefs: Exemptions: securities issued or raised by non-UK companies Stamp Duty Reserve Tax (SDRT)

FA86/S99(4) provides that securities issued or raised by non-UK-incorporated companies are not chargeable securities for Stamp Duty Reserve Tax unless:

  • they are registered on a register in the UK (sub-section (a)), or
  • they are shares paired with shares in a UK incorporated company (sub-section (b)), or
  • they are interests in (or rights to) securities in either of the above two cases (sub-section (c)), or
  • they are certain securities raised or issued by a Societas Europaea (European Company) (sub-section (d)).

There is no equivalent exemption for stamp duty.