Administration and enforcement of SDRT
Administration and enforcement of SDRT

The following Tax practice note provides comprehensive and up to date legal information covering:

  • Administration and enforcement of SDRT
  • HMRC guidance—Stamp Taxes on Shares Manual
  • Territorial scope
  • Liability and accountability for the principal charge to SDRT
  • Liability and accountability for the higher rate SDRT charge
  • General rule
  • Exceptions to the general rule
  • Practical implications
  • Notification and payment obligations
  • Due date for payment
  • More...

This Practice Note deals with the administration and enforcement provisions applicable to the principal charge and the higher rate charge to stamp duty reserve tax (SDRT). In this Practice Note, the Stamp Duty Reserve Tax Regulations 1986, SI 1986/1711, are referred to as the SDRT Regs.

Before delving into the detail of how SDRT is administered, it is useful to note that, subject to exemptions, SDRT applies to:

  1. agreements (whether oral or written) to transfer chargeable securities for consideration in money or money's worth (including deemed consideration in accordance with the listed securities market value rule or the unlisted securities market value rule) at a rate of 0.5% (and, if this sum is not a multiple of one penny, it is rounded to the nearest penny), known as the principal charge to SDRT, and

  2. transfers or appropriations of chargeable securities to any depositary or any operator of clearance services (or their nominees) at a rate of 1.5% (and, if this sum is not a multiple of one penny, it is rounded to the nearest penny), known as the higher rate charge, provided that, in respect of a transfer of UK shares or loan capital, the transfer is not an integral part of an issue of share capital or the raising of capital

The special SDRT regime, known as the Schedule 19 charge, that used to apply

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