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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: scope of 1.5 per cent charge: 1.5 per cent Stamp Duty charge - transfer of securities

A charge to stamp duty at the rate of 1.5 per cent arises on any instrument that transfers (whether on sale or otherwise than on sale) relevant securities to a depositary receipt issuer (or to its agent or nominee) or clearance service (or to its agent or nominee). The scope of the charge however is restricted to relevant securities of a company that is incorporated in the United Kingdom.

‘Relevant securities’ for the purposes of a 1.5per cent stamp duty charge means shares in or stock or marketable securities of a United Kingdom incorporated company.

The stamp duty 1.5 per cent charge does not, however, extend to relevant securities of a United Kingdom incorporated company that are raised or issued to a depositary receipt issuer or clearance service. The reason for this is that as the creation and issue of shares vest upon registration and no instrument of transfer, upon which stamp duty might otherwise be payable, is required.