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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Collectives: the Schedule 19 charge: scope of Stamp Duty Reserve Tax charge (SDRT)

A charge to Stamp Duty Reserve Tax (SDRT) under FA99/SCH19 can arise on the surrender of a unit in a unit trust or a share in an Open-Ended Investment Company (OEIC) provided such units or OEIC shares come within the definition of ‘chargeable securities’ for the purposes of FA86/S99(3) . This generally means that the units or OEIC shares must be in:

  • a unit trust or OEIC fund which is incorporated in the United Kingdom (UK); or
  • a unit trust or OEIC fund where the trustees of the fund are resident within the UK; or
  • an overseas OEIC that keeps and maintains a register of its shares in the UK; or
  • a unit trust/OEIC, the terms of which the trust or OEIC property is able to invest in and hold investments that come within the definition of ‘chargeable securities’ at FA86/S99(3) .

In this situation, the FA99/SCH19 SDRT charge is mandatory and global, and arises irrespective of whether the surrender of units/OEIC shares was made or effected in the UK or whether any party to the transaction is resident or located within or outside of the UK (Regulation 2(2) of FA99/SCH99).

See STSM101020 for the meaning of a unit trust.

See STSM101050 for the meaning of an Open-Ended Investment Company (OEIC).