The following Tax practice note provides comprehensive and up to date legal information covering:
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:
agreements (whether oral or written) to transfer chargeable securities for consideration in money or money's worth at a rate of 0.5%, known as the principal charge, and
transfers or appropriations of chargeable securities into depositary receipt systems or clearance services at a rate of 1.5%, known as the higher rate charge, provided that the transfer is not an integral part of an issue of share capital—the legislation though still reads as if a higher rate SDRT charge applies to an issue of chargeable securities into such a system or service. According to HMRC (and as set out in the Stamp Taxes Bulletin 2/2012), the SDRT treatment on issue of chargeable securities other than UK shares and loan capital will 'be determined on a case by case basis in view of the specific facts of a given case, the terms of the capital duty directive and the decisions in Vidacos and HSBC/Mellon'
The special SDRT regime, known as the
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This Practice Note provides an introduction to intercreditor agreements and their key provisions. This Practice Note:•explains the purpose of having an intercreditor agreement and when an intercreditor agreement would be used instead of a deed of priority or subordination deed•provides links to
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BREXIT: As of 31 January 2020, the UK is no longer an EU Member State, but has entered an implementation period during which it continues to be treated by the EU as a Member State for many purposes. As a third country, the UK can no longer participate in the EU’s political institutions, agencies,
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