1185. Overview of higher-rate charge to stamp duty reserve tax in respect of arrangements; depositary receipts.

Subject to certain exceptions1, a charge to stamp duty reserve tax is made where in pursuance of an arrangement:

  1.  

    (1)     a person whose business is or includes issuing depositary receipts for chargeable securities2 has issued or is to issue such a depositary receipt3; and

  2.  

    (2)     chargeable securities of the same kind and amount are transferred or issued either to the person mentioned in head (1) above, or to a person whose business is or includes holding chargeable securities as nominee or agent for the person who has issued or is to issue the depositary receipt4, or are appropriated by