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Stamp duty reserve tax

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Latest Tax News

Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

The following Commercial news provides comprehensive and up to date legal information on Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

Tax weekly highlights—8 April 2021

Tax weekly highlights—8 April 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—8 April 2021

UT reinstates follower notice penalty (HMRC v Comtek)

UT reinstates follower notice penalty (HMRC v Comtek)

The following Private Client news provides comprehensive and up to date legal information on UT reinstates follower notice penalty (HMRC v Comtek)

Tax weekly highlights—1 April 2021

Tax weekly highlights—1 April 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—1 April 2021

Featured Tax content

What is an intangible fixed asset?

What is an intangible fixed asset?

Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...

SDLT—deeds of rectification

SDLT—deeds of rectification

Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...

Bank levy

Bank levy

FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...

Practice notes

Unilateral relief for foreign tax

Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes

Plant and machinery allowances—definition of plant and machinery

Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes

VAT on composite supplies

Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes

Why have a tax covenant?

It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes

Capital reduction demergers

The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes

Section 198 and 199 elections on transactions involving real estate

This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
tag iconIn-house
Practice notes

Schemes of reconstruction defined

This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes

What is a tax determination?

This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes

VAT treatment of damages and compensation payments

A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
tag iconIn-house
Practice notes

EIS funds, including approved knowledge-intensive funds

The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes

Property authorised investment funds (PAIFs)—summary

The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Practice notes

Management buyouts—summary of tax issues for management

A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes

Tax considerations on a loan agreement—the tax indemnity clause

This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Stamp duty reserve tax content

Practice notes

Intermediaries relief from stamp duty and SDRT

Coronavirus (COVID-19) impact on stamp duty process: During the coronavirus outbreak, the Stamp Office is temporarily only accepting electronic...
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Produced in partnership with Kevin Griffin 9th Apr
Practice notes

Loan capital exemption from stamp duty

Debt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions aimed at ensuring that it is a normal...
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9th Apr
Practice notes

Stamp duty reserve tax on the sale of UK shares held in CREST

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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9th Apr
Practice notes

Higher rate SDRT and stamp duty charges

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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9th Apr
Practice notes

Interaction between SDRT and stamp duty

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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9th Apr
Practice notes

Stamp duty reserve tax—when it applies

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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9th Apr
Practice notes

Exemptions from the higher rate charges to stamp duty and SDRT

Executive summaryWhen securities are transferred into a depositary receipt system or a clearance service, a 1.5% charge to stamp duty or SDRT...
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9th Apr
Practice notes

Growth market exemption from stamp duty and SDRT

Since 28 April 2014, no stamp duty or stamp duty reserve tax (SDRT) is chargeable on a transfer of shares or securities that are:•admitted to trading...
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9th Apr
Practice notes

Stock lending and repo relief from stamp duty and SDRT

Coronavirus (COVID-19) impact on stamp duty process: During the coronavirus outbreak, the Stamp Office is temporarily only accepting electronic...
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Produced in partnership with Kevin Griffin 9th Apr
Practice notes

Administration and enforcement of SDRT

This Practice Note deals with the administration and enforcement provisions applicable to the principal charge and the higher rate charge to stamp...
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9th Apr
Practice notes

Sukuk—investment bond arrangements and stamp duty and SDRT

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Sarah Squires of Old Square Tax Chambers 9th Apr
Practice notes

Stamp duty and SDRT and depositary interests in foreign shares

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...
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9th Apr
Practice notes

Public offer relief from SDRT

When a company’s securities are first listed on the main market of the London Stock Exchange (LSE), one or more banks (and/or other financial...
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Produced in partnership with Kevin Griffin 9th Apr
Practice notes

Exemptions from the principal charge to SDRT

Executive summaryAn agreement to transfer chargeable securities for consideration (or, in certain circumstances where either of the SDRT market value...
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9th Apr
Q&As

Must the issuer of an instrument be regulated (for instance, by the Prudential Regulation Authority) in order for that instrument to be able to qualify as a regulatory capital security under the Taxation of Regulatory Capital Securities Regulations 2013, SI 2013/3209 on the basis of being an Additional Tier 1 instrument under the Capital Requirements Regulations?

Regulatory capital securities, broadly, means securities issued by financial institutions and insurance companies to meet their regulatory capital...
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8th Apr
Practice notes

Stamp duty and stamp duty reserve tax implications of stabilisation transactions, including the over-allotment or greenshoe option

In the context of an offering of shares to the public by way of an initial public offering (IPO) or a secondary offering of shares, this Practice Note...
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1st Mar
Q&As

Does stamp duty reserve tax (SDRT) apply to the transfer of shares in a Gibraltar incorporated company?

Subject to exemptions, stamp duty reserve tax (SDRT) applies to:•agreements (whether oral or written) to transfer chargeable securities for...
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15th Feb
Q&As

According to section 89AA(2A) of the Finance Act 1986, one of the conditions that must be satisfied in order for relief from SDRT to be available for repos or stock lending arrangements requires that ‘securities of the kind concerned are regularly traded on a regulated market’. What does ‘regularly traded’ and ‘securities of the kind concerned’ mean?

As noted in Practice Note: Stock lending and repo relief from stamp duty and SDRT, for the relief from SDRT to apply to a repo or stock lending...
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15th Feb
Q&As

Does stamp duty apply to the assignment of a life insurance policy?

The stamp tax analysis of an assignment of a life insurance policy will depend on the mechanics of the assignment and whether the policy is a...
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15th Feb
Q&As

Does UK stamp duty or stamp duty reserve tax (SDRT) apply to the grant of an option (that is governed by English law) to acquire shares that are issued by a non-UK company?

SDRT does not arise on the grant of an option, however, it could arise on an assignment of the option. The grant of an option does not involve a...
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Produced in partnership with Sean Randall of Blick Rothenberg 15th Feb

Popular documents

LEXISNEXIS

Proprietary estoppel

This Practice Note considers proprietary estoppel from a generic standpoint.For industry specific guidance on proprietary estoppel, see Practice Notes:•Estoppel and property law•Mortgages by estoppelProprietary estoppel—what is it?Unlike the other forms of estoppel (see Practice Note: Estoppel—what,

LEXISNEXIS

Separation of powers—legislative, executive and judiciary

Source of the doctrine of the separation of powersThe origins of the doctrine are often traced to John Locke’s Second Treatise of Government (1689), in which he identified the 'executive' and 'legislative' powers as needing to be separate.‘… it may be too great a temptation to human frailty, apt to

LEXISNEXIS

Forum non conveniens—scope and application

This Practice Note considers the doctrine of forum non conveniens, also referred to as the appropriate forum or the proper place for a dispute to be determined. This doctrine is of relevance when determining whether the courts of England and Wales have jurisdiction to hear a dispute and is applied

LEXISNEXIS

Mistake in contract law

This Practice Note considers the legal concept of mistake in contract law. It examines common mistake, mutual mistake, unilateral mistake, mistake as to identity and mistake as to the document signed (non est factum). It also considers the impact of each of these types of mistake on the contract and