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HMRC internal manual

Stamp Taxes on Shares Manual

Depositary receipt and clearance services: scope of 1.5 per cent charge: 1.5 per cent Stamp Duty charge - overseas branch register

Where a United Kingdom company keeps or maintains a register of its shares in an overseas branch register in certain prescribed countries as listed in CA2006/S129 (2), any relevant securities traded and transferred from the overseas branch register (on sale or otherwise than on sale) to a depositary receipt issuer or clearance service are not chargeable with stamp duty by virtue of CA2006/S133 (3), provided that no instrument of transfer is executed in the United Kingdom.

For Stamp Duty Reserve Tax (SDRT) implications, see STSM055100.

See STSM053020 for the meaning of relevant securities.