Stamp taxes on shares consideration rules
Read the full outcome
Detail of outcome
The Finance Act 2018 to 2019 introduced a targeted market value rule to prevent contrived arrangements involving transfers of listed securities to connected companies to minimise stamp taxes on shares liability.
Following a consultation, the government has published draft legislation extending the market value rule to the transfer of unlisted shares to a connected company.
This also removes an anomaly where a double charge can arise on certain company reorganisations.
The government also consulted on aligning the Stamp Duty and Stamp Duty Reserve Tax definitions of what constitutes 鈥榗onsideration鈥�, and on the rules on contingent consideration but has decided not to make a legislative change now.
Following this consultation, the government has published draft legislation, explanatory notes and a tax information and impact note (TIIN).
Original consultation
Consultation description
We welcome views from businesses, legal firms, accountants and other interested parties on the impacts of:
- extending the market value rule introduced on Budget Day 2018 and legislated for in Finance Bill 2018 to 2019
- adopting the SDRT definition of consideration for Stamp Duty
- aligning the contingency rules, and the most practical way of doing this