The following Corporate guidance note provides comprehensive and up to date legal information covering:
STOP PRESS relating to market value consideration for transfers of listed securities to connected companies: Finance Act 2019 introduced a targeted market value rule for stamp duty and SDRT for instruments transferring or agreements to transfer listed securities (ie stock or marketable securities orc hargeable securities that are regularly traded on a regulated market, multilateral trading facility or recognised foreign exchange) to connected companies. For such transfers, the consideration chargeable to stamp duty or SDRT will be the higher of the consideration (if any) given for the transfer or the market value of the listed securities. This provision took effect retrospectively from 29 October 2018.
STOP PRESS relating to exemptions from stamp duty and SDRT (hybrid capital and financial bail-in):
Finance Act 2019 introduced a new regime for the taxation of hybrid capital instruments that replaced the regime for the taxation of regulatory capital securities with effect from 1 January 2019, and inserted new provisions in the loan relationships rules in Part 5 of Corporation Tax Act 2009 (CTA 2009) (for which see Practice Note: Scope of the loan relationships regime—Definition of loan relationship—specific cases) and, subject to transitional provisions, revoked the Taxation of Regulatory Capital Securities Regulations 2013, SI 2013/3209 (RCS Regs) but also included:
a provision clarifying that the revocation of the RCS Regs only took effect from
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