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HMRC internal manual

Stamp Taxes on Shares Manual

Depositary receipt and clearance services: exemptions/reliefs: securities issued or raised by companies incorporated outside of the United Kingdom

A 1.5 per cent Stamp Duty Reserve Tax (SDRT) charge under the provisions of FA86/S93 or FA86/S96 arises only where securities in a company incorporated in the United Kingdom (UK) are deposited with a depositary receipt issuer or clearance service scheme. See FA86/S67(1), FA86/S70(1) and FA86/S99 (10).

The 1.5 per cent higher rate charge does not, unlike the principal SDRT charge at the rate of 0.5 per cent ( FA86/S87 ), extend to securities, including bearer securities, in companies that are incorporated outside of the UK, including non-UK incorporated companies that maintain or keep a register of their shares in the UK.