Exemption ― finance ― securities

Produced by Tolley

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

  • Exemption ― finance ― securities
  • Securities
  • Securities for money
  • Guarantees and surety bonds
  • Shares, securities and other financial instruments
  • VAT treatment of security transactions other than share issues
  • International security transactions (until 31 December 2020)
  • International security transactions (from 1 January 2021)
  • International security transactions ― the easement
  • VAT treatment of share issues
  • More...

Exemption ― finance ― securities

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marked the end of the Brexit transition / implementation period entered into following the UK’s withdrawal from the EU. At this point in time, key transitional arrangements came to an end and significant changes began to take effect across the UK’s VAT and customs regime. This document contains guidance on subjects potentially impacted by these changes. Before continuing your research, see the Brexit — overview guidance note.

This guidance note covers the VAT treatment of various types of financial securities.


The issue, transfer or receipt of, or any dealing with, any security or secondary security in the UK is exempt from VAT (but see the impact of the Kretztechnik decision in ‘VAT treatment of share issues’ below). For these purposes, a security or secondary security comprises:

  1. shares, stock, bonds, notes (other than promissory notes), debentures, debenture stock or shares in an oil royalty

  2. 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

  3. 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

  4. 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

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