Consultation outcome

Stamp taxes on shares consideration rules

From:: HM Revenue & Customs
Published: 7 November 2018
Last updated: 11 July 2019 — See all updates

Read the full outcome

Stamp taxes on shares: rules consideration - summary of responses

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Detail of outcome

The Finance Act 2018 to 2019 introduced a targeted market value rule to prevent contrived arrangements involving transfers of listed securities to connected companies to minimise stamp taxes on shares liability.

Following a consultation, the government has published draft legislation extending the market value rule to the transfer of unlisted shares to a connected company.

This also removes an anomaly where a double charge can arise on certain company reorganisations.

The government also consulted on aligning the Stamp Duty and Stamp Duty Reserve Tax definitions of what constitutes ‘consideration’, and on the rules on contingent consideration but has decided not to make a legislative change now.

Following this consultation, the government has published draft legislation, explanatory notes and a tax information and impact note (TIIN).

Original consultation

Consultation description

We welcome views from businesses, legal firms, accountants and other interested parties on the impacts of:

extending the market value rule introduced on Budget Day 2018 and legislated for in Finance Bill 2018 to 2019
adopting the SDRT definition of consideration for Stamp Duty
aligning the contingency rules, and the most practical way of doing this

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