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HMRC internal manual

Stamp Taxes on Shares Manual

Depositary receipt and clearance services: scope of 1.5 per cent charge: Stamp Duty Reserve Tax - secondary trading of allotment letter / RLA already deposited with a depositary receipt issuer or clearance service

The secondary trading of rights or interests (whether nil, partly or fully paid) to an allotment of or to subscribe for, stocks, shares or loan capital in depositary receipt form, or within a clearance service, is not subject to a 0.5 per cent or 1.5 per cent Stamp Duty Reserve Tax (SDRT) charge by virtue of FA86/90 (5) and FA86/S99 (6).

See STSM055030 for the meaning of an allotment letter and a renounceable letter of allotment.