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HMRC internal manual

Stamp Taxes on Shares Manual

Trusts and pension schemes: pension schemes: contributions of assets to an occupational pension, personal pension scheme or Self Invested Personal Pension - general

If an individual or employer wants to invest stock or marketable securities into an occupational pension scheme, personal pension scheme or Self-Invested Pension Plan (SIPP) they must define the value of their contribution in cash terms. This debt is then settled by transferring their stock or marketable securities to the SIPP so in this case ad valorem stamp duty is payable.

For Stamp Duty Reserve Tax (SDRT) purposes, the agreement to transfer chargeable securities to the occupational pension, personal pension scheme or SIPP constitutes money’s worth (the forgiveness of the debt) and an SDRT charge therefore arises.

For both stamp duty and SDRT the transfer constitutes an in specie contribution for which consideration has been given.