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HMRC internal manual

Stamp Taxes on Shares Manual

Exemptions and Reliefs: Exemptions: units in a unit trust scheme or shares in an open-ended investment company

FA99/SCH19PARA1(1) provides an exemption from stamp duty on a transfer or other instrument relating to a unit under a unit trust scheme. This applies equally to shares in Open-Ended Investment Companies (OEICs). The exemption does not prevent such units or shares being treated as consideration for stamp duty purposes nor does it affect any charge relating to bearer instruments.

Units under a unit trust scheme and shares in an OEIC are, however, regarded as ‘chargeable securities’ for the purposes of a charge to Stamp Duty Reserve Tax (SDRT) unless they fall within the exception FA86/S99(5A) (see STSM105010). Surrenders of units or OEIC shares to the fund manager (or equivalent) are exempt from a FA86/S87 SDRT charge by section 90(1) of that Act (see STSM103080).