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HMRC internal manual

Stamp Taxes on Shares Manual

From
HM Revenue & Customs
Updated
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Depositary receipt and clearance services: 1.5 per cent higher rate charge: Stamp Duty Reserve Tax - chargeable securities

For the purposes of a 1.5 per cent Stamp Duty Reserve Tax (SDRT) charge under FA86/S93(4) and FA86/S96(2), the provisions of FA86/S99 (3) define chargeable securities as:

  • stocks, shares or loan capital;
  • interests in, or in dividends or other rights arising out of, stocks, shares or loan capital,
  • rights to allotments of or to subscribe for, or options to acquire, stocks shares or loan capital, and
  • units under a unit trust scheme or shares in an open-ended investment company.

Unlike the principal 0.5 per cent SDRT charge under FA86/S87 that applies when chargeable securities are agreed to be transferred for money or money’s worth, the 1.5 per cent SDRT charge does not apply to securities that are issued or raised by a non-United Kingdom company that keeps a register of its shares in the United Kingdom (FA86/S99 (10)(a)).

The 1.5 per cent higher rate charge does, however, apply to shares held on an overseas branch register maintained by or on behalf of a United Kingdom company ( FA86/S99 (10)(b)).

See STSM055020 for information on overseas branch registers.