STSM013030 - Introduction to Stamp Duty on shares and Stamp Duty Reserve Tax (SDRT): Stamp duty rates: Stamp Duty - transfers to clearance services and depositary receipt Issuers

The higher 1.5% Stamp Duty charge applies to instruments that:

  • Transfer relevant securities to a depositary receipt issuer or their nominee (section 67 FA1986)
  • Transfer relevant securities to a clearance service or their nominee (section 70 FA1986)

The 1.5% charge does not apply to exempt capital raising instruments (see STSM053100) and exempt listing instruments (see STSM053110).

No 1.5% charge arises on the issue of relevant securities to a depositary receipt issuer or clearance service.

Calculation of the 1.5% Stamp Duty charge


Clearance Services

Where the instrument represents a transfer of securities on sale, the 1.5% charge is calculated by reference to the amount or value of the consideration paid (section 70(2) FA1986). Where an instrument represents a transfer of securities otherwise than on sale, the 1.5% charge is calculated by reference to the value of the securities at the date the instrument is executed (section 70(3) FA1986). Further information is at STSM052020.

Depositary Receipt Issuers

Where the instrument represents a transfer of securities on sale, the 1.5% charge is calculated by reference to the amount or value of the consideration paid (section 67(2) FA1986). Where an instrument represents a transfer of securities otherwise than on sale, the 1.5% charge is calculated by reference to the value of the securities at the date the instrument is executed (section 67(3) FA1986). Further information is at STSM051030.

Transfers related to options

Where an instrument transferring securities in a UK company is executed pursuant to the exercise of an option to buy or sell the securities and the transfer is to a clearance service or depositary receipt issuer (or to their respective nominees), a 1.5% charge is calculated by reference to (a) the amount or value of the consideration paid for the sale or (b) the value of the UK securities at the date the transfer instrument is executed, whichever is the higher.

In all of the above cases the rounding provisions of section 112(1) FA1999 apply. See STSM013040.