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HMRC internal manual

Stamp Taxes on Shares Manual

Stamp duty and SDRT Administration: SDRT Administration: documents unstamped at the accountable date

Documents unstamped at the ‘accountable date’

It should normally be possible for routine applications for stamping to be processed quickly, and so it is likely in practice that stock transfer forms or other relevant documents will have been stamped before the Stamp Duty Reserve Tax (SDRT) accountable date if this is the wish of the accountable person. In these cases SDRT does not fall to be considered. However there are some circumstances where it may be difficult for a document to be stamped before the accountable date:

  • ‘Wait and see’ cases. The first is where the consideration is not ascertainable by the accountable date or completion is not possible by that date; although full ad valorem duty will eventually be paid.
  • Adjudicated relief cases. The second scenario is where the stamp duty is likely to be nominal or nil (e.g. because an exemption is being claimed) but the adjudication process is not concluded by the accountable date. This should not happen very often as we are usually able to respond quickly to routine applications if these are made in good time.

Cases where there is difficulty in securing stamping of the documents should be referred to HMRC SDRT Operations for SDRT to be pursued if the SDRT charge seems likely to be open for more than three months or if the amount is large.