The following Tax guidance note Produced in partnership with Kevin Griffin provides comprehensive and up to date legal information covering:
This practice note explains:
what depositary interests (DIs) are and why they are used
why stamp duty is unlikely to apply to transfers of UK issued DIs
the conditions that must be satisfied for relief from SDRT to apply to a transfer of DIs
how the relief is obtained, and
the notification obligations imposed when the SDRT relief applies
HMRC's guidance on stamp duty and SDRT is now found in the Stamp Taxes on Shares Manual (STSM), which has replaced the old Stamp Taxes Manual. The old Stamp Taxes Manual is still available online as a PDF document (for which click here). It was last updated in 2001. The old manual is out of date and potentially misleading.
In this practice note, references to the old manual have been replaced with references to STSM. Even the new STSM, however, is not fully up to date. It has, for instance, not yet been updated to reflect the abolition of the Schedule 19 charge or the introduction of the exemption for unlisted securities admitted to trading on a recognised growth market.
A depositary interest (DI) is a security issued by a depositary in country X, representing a security issued in country Y. Those issued outside the UK are often referred to
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