Higher rate SDRT and stamp duty charges
Higher rate SDRT and stamp duty charges

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

  • Higher rate SDRT and stamp duty charges
  • Executive summary
  • HMRC guidance—Stamp Taxes on Shares Manual
  • Definitions and relevant concepts
  • Meaning of clearance service and depositary receipt system
  • No higher rate SDRT charges on issue of shares or loan capital
  • Higher rate charges on transfer—SDRT and stamp duty
  • Questionable legality of higher rate charges
  • Implications of entry into a depositary receipt system or a clearance service
  • Section 97A elections
  • more

FORTHCOMING CHANGE on extending market value rule to transfers of unlisted securities to connected companies: Following a consultation on aligning the stamp duty and SDRT consideration rules that ran until 30 January 2019, Finance Bill 2019–20 extends, with effect from Royal Assent, the market value rule for stamp duty and SDRT purposes to transfers of unlisted securities to connected companies (ie where the transferor is (or is the nominee for a person that is) connected with the transferee company) but only where some or all of the consideration consists of the issue of shares. In its summary of responses to that consultation, HMRC confirms that, at this time, it will not be taking forward any of the other proposals made in the consultation. For more information, see News Analysis: Draft Finance Bill 2019–20—Tax analysis—Stamp taxes on securities—extension of market value rule to transfers of unlisted securities to connected companies and for more information on the original consultation, see News Analysis: Exploring the stamp taxes on shares consideration rules consultation.

Higher rate charges refer to the circumstances when SDRT or stamp duty is charged at 1.5% instead of the usual 0.5% rate.

This higher rate charge is referred to as a season ticket because it was intended to be charged on entry (whether by issue or transfer) into a depositary receipt system or