Exempt finance – securities

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Exempt finance – securities
  • Securities
  • Securities in money
  • Shares, securities and other financial instruments
  • VAT treatment of security transactions
  • International security transactions
  • Anti-avoidance - off-shore looping
  • Conclusion

This guidance note covers the VAT treatment of various types of financial securities. Financial securities are 'financial assets'.

VATA 1994, Sch 9, Part II, Group 5, item 6; Directive 2006/112/EC , Article 135(1) (f); De Voil V4.136E (subscription sensitive); VATFIN4000; VAT Notice 701/49 

VATA 1994, Sch 9, Group 5, Item 6

The issue, transfer or receipt of, or any dealing with, any security or secondary security in the UK is exempt from VAT. For these purposes, a security or secondary security comprises:

  • shares, stock, bonds, notes (other than promissory notes), debentures, debenture stock or shares in an oil royalty
  • any document relating to money, in any currency, which has been deposited with the issuer or some other person, being a document which recognises an obligation to pay a stated amount to bearer or to order, with or without interest, and being a document by the delivery of which, with or without endorsement, the right to receive that stated amount, with or without interest, is transferable
  • any bill, note or other obligation of the Treasury or of a Government in any part of the world, being a document by the delivery of which, with or without endorsement, title is transferable, and not being an obligation which is or has been legal tender in any part of the world
  • any letter of allotment or rights, any warrant conferring an option to acquire a security included in these provisions, any renounceable or scrip certificates, rights coupons, coupons representing dividends or interest on such a security, bond mandates or other documents conferring or containing evidence of title to or rights in respect of such a security
  • units or other documents conferring rights under any trust established for the purpose, or having

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