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Avoiding stamp tax traps on IPOs

Toby Price and Martin Walker (Deloitte) consider the potential stamp tax traps arising on IPOs, including pre-IPO reorganisations and overallotment (or greenshoe) options, as well as offering practical solutions


2014 is set to be a record breaking year in the UK market for initial public offerings (IPOs). UK incorporated companies remain the issuer vehicle of choice which contributes to the UK exchequer’s revenues from stamp tax (by which we mean stamp duty and SDRT). Even ignoring stamp tax on future trading in secondary markets 0.5% stamp tax on the large amounts of capital raised on the secondary part of the IPO can itself amount to a material number. Stamp taxes need therefore to be actively managed to ensure that no unexpected charges arise.

hile the facts of each IPO will differ in our experience stamp tax...

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