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HMRC internal manual

Stamp Taxes on Shares Manual

Depositary receipt and clearance services: depositary receipt: higher rate charge on depositary receipt issuers

When ‘stock or marketable securities’ or ‘chargeable securities’ are transferred for consideration, a stamp duty or Stamp Duty Reserve Tax (SDRT) charge will generally arise at the rate of 0.5 per cent by virtue of FA99/SCH13/PARA 1-3 and FA86/S87.

But when, for stamp duty purposes, ‘relevant securities’, or, for SDRT purposes, ‘chargeable securities’, are transferred to a depositary receipt issuer or its nominee in return for the issue of a depositary receipt by the depositary, a stamp duty or SDRT charge at the higher rate of 1.5 per cent may arise. See STSM053000 for details of the Higher Rate charge.

For the meaning of ‘relevant securities’ and ‘chargeable securities’, see STSM053020 and STSM053030.