STSM041070 - Exemptions and reliefs: exemptions: loan capital exemption - miscellaneous

Other Specific Loan Capital Exemptions

Transfers of loan capital issued by the following are also exempt from stamp duty under separate legislation:

  • »Ê¹ÚÌåÓýapp International Bank of Reconstruction and Development
  • »Ê¹ÚÌåÓýapp EEC
  • »Ê¹ÚÌåÓýapp European Coal and Steel Community
  • »Ê¹ÚÌåÓýapp European Atomic Energy Authority
  • »Ê¹ÚÌåÓýapp European Investment Bank

Convertible Notes

Transfers of Convertible Notes are liable to stamp duty. Sometimes building societies have or issue Convertible Notes which automatically convert into Permanent Interest Bearing Shares (PIBS) within a few months. »Ê¹ÚÌåÓýapp Notes are loan capital but the conversion rights attached to them deny the exemption applicable to the transfer of loan capital by virtue of Section 79(5) Finance Act 1986. »Ê¹ÚÌåÓýappse transfers should not be confused with the transfers of PIBS which are exempt. (See STSM021230, STSM021240 and STSM041100).