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HMRC internal manual

Stamp Taxes on Shares Manual

Stamp Duty and SDRT Administration: Stamp Duty Administration: calculating the duty payable

The stamp duty chargeable on an instrument of transfer must be carefully considered and must always be supported by the authority of the Stamp Act and its amending Acts. If a customer objects to HMRC’s calculation and requires a more formal opinion the document must be lodged for adjudication (see STSM012020). Any person may request HMRC to formally adjudicate an instrument in respect of the amount of stamp duty (Stamp Act 1891/S12).

A person who is dissatisfied with the result of an adjudication may appeal the decision, but only after the duty and any interest and/or penalty has been paid. An appeal is to the High Court unless it relates only to a penalty for late stamping in which case it is to the First-tier Tribunal (Stamp Act 1891/S13).