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HMRC internal manual

Stamp Taxes on Shares Manual

Trusts and pension schemes: Stamp Duty on declarations of trust on or after 13 March 2008

A declaration of trust executed on or after 13 March 2008 is not chargeable with stamp duty unless its true effect is that it constitutes a transfer on sale of stock or marketable securities. A declaration of trust made by a seller in favour of a buyer is a transfer on sale chargeable with ad valorem stamp duty (Chesterfield Brewery Company v IRC [1899] 2 QB 7).