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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Trusts and pension schemes: agreement or contract for the transfer of stock, marketable securities or chargeable securities incorporating a declaration of trust

A written contract or agreement to transfer on sale the legal title to stock or marketable securities is not normally within the scope of FA99/SCH13/PARA7 because there is no change of beneficial ownership. The agreement will immediately become chargeable with ad valorem duty if the vendor declares that he holds the beneficial ownership of the securities on trust for the purchaser, so that the contract effectively transfers both legal and beneficial ownership.