STSM031010 - Scope of Stamp Duty Reserve Tax (SDRT): rates of tax

A charge to Stamp Duty Reserve Tax (SDRT) under section 87 FA1986 arises where a Person (A) agrees with another Person (B) to transfer chargeable securities (whether or not to Person (B)) for consideration in money or money’s worth. »Ê¹ÚÌåÓýapp charge applies:

  • whether or not there is an instrument  or other document is executed completing the transfer;
  • whether or not settlement of the transfer takes place;
  • whether or not the agreement to transfer is made or effected in the UK or overseas; and
  • regardless of whether the parties to the agreement to transfer re resident in the UK or eslewhere.

»Ê¹ÚÌåÓýapp principal charge to SDRT is at the rate of 0.5% of the amount or value of the consideration paid in money or money's worth.

»Ê¹ÚÌåÓýapp value of any consideration not consisting of money shall be taken to be the price it might reasonably be expected to fetch on a sale in the open market at the date of the unconditional agreement (section 87(7) FA1986).

Where, within 6 years of the date the SDRT charge arose:

  • the agreement is subsequently completed by a written instrument of transfer i.e. a stock transfer form, or other document effecting the transfer, upon which Stamp Duty is paid and duly stamped, or
  • is stamped so that it is relieved from Stamp Duty, or
  • is otherwise exempt from a Stamp Duty charge, then
  • the SDRT charge is cancelled and any SDRT already paid can be refunded where appropriate (section 92 FA1986).

A higher 1.5% SDRT rate may apply where chargeable securities are transferred (on sale or otherwise than on sale) to an issuer of depositary receipts (or to its nominee) (section 93(1) & (4) FA1986) or to an operator of a clearance service (or its nominee) (section 93 (1) & (2) FA1986).

See STSM031090 for the meaning of ‘chargeable securities�

See STSM031040 for more information on an ‘agreement to transfer�

See STSM031060 for the meaning of ‘money’s worth�

See STSM050000 for information on depositary receipts and clearance services

See STSM053080 onwards for information on changes to domestic legislation on the 1.5% SDRT charge with effect from 1 January 2024.