Intermediaries relief from stamp duty and SDRT
Produced in partnership with Kevin Griffin
Intermediaries relief from stamp duty and SDRT

The following Tax guidance note Produced in partnership with Kevin Griffin provides comprehensive and up to date legal information covering:

  • Intermediaries relief from stamp duty and SDRT
  • HMRC guidance—Stamp Taxes on Shares Manual
  • Qualifying for intermediaries relief
  • Conditions for recognition as an intermediary
  • Categories of recognition as intermediary
  • Conditions for transactions to qualify for relief
  • Obligation on intermediaries to collect SDRT on behalf of HMRC on transfer to end buyer
  • The role of CREST
  • Intermediaries relief supports the market in contracts for differences (CFDs)

Most transactions in publicly traded UK securities involve and take place through one or more intermediaries such as stockbrokers and banks. This is why intermediaries relief from stamp duty and SDRT for transfers of securities is such an important relief. It facilitates the operation of the securities markets, including the market in contracts for differences (CFDs), for which see: Intermediaries relief supports the market in contracts for differences (CFDs).

The basic premise of the relief is that the insertion of one or more intermediaries between a seller and a buyer should not add to the stamp duty or SDRT charge which would have arisen on a direct transfer from the seller to the buyer. For more information on:

  1. SDRT, see: Stamp duty reserve tax—when it applies and

  2. stamp duty, see: What does stamp duty apply to?

As a result of the intermediaries relief, no liability to SDRT arises on most agreements to transfer chargeable securities to recognised intermediaries and no stamp duty arises where such transfers are documented (ie effected by an instrument of transfer such as a stock transfer form).

Normally, a transfer to a recognised intermediary still qualifies for relief even if there is no onward transfer to another purchaser.

This practice note explains:

  1. the nature of recognised intermediary relief from stamp duty and SDRT

  2. the conditions that must be satisfied