IFM10500 - Stamp duty and Stamp duty reserve tax (SDRT)
The issue of units by an unauthorised unit trust (UUT) to the manager or to an investor does not give rise to a liability to stamp duty or SDRT. An UUT will be liable to stamp duty or SDRT in the normal way on purchases of investments that are not exempt.
Where an investor subscribes for units in a UUT by transferring a portfolio of investments to the UUT then stamp duty or SDRT will be payable on all investments other than exempt investments.
If an investor transfers a portfolio of investments that exactly matches or is in proportion to mirrors the scheme property of the UUT there will be no charge to stamp duty or SDRT.
Further information on contributions to unit trusts and the stamp duty and SDRT implications can be found at: STSM107030.