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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Exemptions and Reliefs: Exemptions: interests in depositary receipts and equities within unelected clearance services

Trading of interests in depositary receipts and securities held through a clearance service that has not made an election under FA86/S97A, is exempt from stamp duty as no instrument of title (i.e. stock transfer form) is required to register a change of name on the company’s register. FA86/S99(6) specifically excludes interests in depositary receipts from the definition of chargeable securities for Stamp Duty Reserve Tax purposes.

The depositary receipts can be physically delivered by hand as the name of the receipt holder is not shown on the receipt, and legal title to the underlying securities remains in the name of the depositary bank or clearance service (or its nominee).

See STSM050000 - Depositary Receipts and Clearance Services.