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HMRC internal manual

Stamp Taxes on Shares Manual

Depositary receipt and clearance services: 1.5 per cent higher rate charge: Stamp Duty Reserve Tax cancelled where Stamp Duty paid on a transaction

Under the provisions of FA86/S93 (7) and FA86/S96 (5) the 1.5 per cent Stamp Duty Reserve Tax (SDRT) charge is cancelled if securities transferred to a depositary receipt issuer or clearance service are settled by the execution of an instrument i.e. a stock transfer form, upon which stamp duty at the rate of 1.5 per cent is paid and impressed.

Similarly, by virtue of FA86/S99 (5), there is, generally, no 1.5 per cent SDRT charge on securities the transfer of which will be exempt from all stamp duty, but a charge is imposed upon securities of United Kingdom companies that are listed on an overseas branch register by virtue of FA86/S99 (10). See STSM055020.