Bridget English and Richard Sultman (Cleary Gottlieb Steen & Hamilton) discuss the proposed extension of the stamp duty/SDRT market value rule.
Stamp duty and SDRT charges are generally calculated by reference to the value of the consideration given for the securities transferred or agreed to be transferred (FA 1999 Sch 13 para 4 and FA 1986 s 87(6)). However since last year stamp duty/SDRT payable on connected-company transfers of listed securities is instead calculated by reference to the market value of the securities which are the subject of the transfer/agreement if that is higher (FA 2019 ss 47 and 48).
At the same time HMRC also launched a consultation proposing the extension of the rule to all transfers of or agreements to transfer unlisted securities between connected (legal or natural) parties with a view to ‘minim[ising] the scope for continuing avoidance’. Thankfully ...
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Bridget English and Richard Sultman (Cleary Gottlieb Steen & Hamilton) discuss the proposed extension of the stamp duty/SDRT market value rule.
Stamp duty and SDRT charges are generally calculated by reference to the value of the consideration given for the securities transferred or agreed to be transferred (FA 1999 Sch 13 para 4 and FA 1986 s 87(6)). However since last year stamp duty/SDRT payable on connected-company transfers of listed securities is instead calculated by reference to the market value of the securities which are the subject of the transfer/agreement if that is higher (FA 2019 ss 47 and 48).
At the same time HMRC also launched a consultation proposing the extension of the rule to all transfers of or agreements to transfer unlisted securities between connected (legal or natural) parties with a view to ‘minim[ising] the scope for continuing avoidance’. Thankfully ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
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