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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Depositary receipt and clearance services: calculation of 1.5 per cent Stamp Duty/Stamp Duty Reserve Tax charge: interaction of Stamp Duty and Stamp Duty Reserve Tax 1.5 per cent charge

The provisions of FA86/S93 (7) and FA86/S96 (5) ensure that any stamp duty paid (whether at 0.5 per cent or 1.5 per cent) on an instrument effecting a transfer of securities is offset against any Stamp Duty Reserve Tax (SDRT) liability. Clearly, if an instrument has been executed upon which stamp duty at the rate of 1.5 per cent has been paid and impressed, this may well cancel the whole SDRT charge.