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HMRC internal manual

Stamp Taxes on Shares Manual

HM Revenue & Customs
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Collectives: exemptions: exempt collective investment schemes

A unit in a unit trust scheme or a share in an Open-Ended Investment Company (OEIC) is not regarded as a ‘chargeable security’ for the purposes of a charge to stamp duty reserve tax under FA99/SCH19 (or FA86/S87) by virtue of FA86/S99(5A) if:-

  • all the trustees under the scheme are resident outside of the United Kingdom, and no register of the units or OEIC shares is kept in the United Kingdom by or on behalf of the trustees under the scheme; or
  • under the terms of the scheme, the trust fund or OEIC can only be invested in property which is regarded as an exempt investment.

See STSM101020 for the meaning of a unit trust.

See STSM101050 for the meaning of an open-ended investment company.

See STSM105020 and STSM105050 for the meaning of exempt investments.

See STSM031090 for the meaning of chargeable securities.