188体育

Exchange tokens could be given as consideration for purchases of 鈥榮tock or marketable securities鈥� and/or 鈥榗hargeable securities鈥�.

For Stamp Duty, chargeable consideration is 鈥榤oney鈥�, 鈥榮tock or marketable securities鈥� or 鈥榙ebt鈥�. For SDRT it is defined as 鈥榤oney or money鈥檚 worth鈥�.

If exchange tokens are given as consideration, this would count as 鈥榤oney鈥檚 worth鈥� and so be chargeable for SDRT purposes. Tax will be due based on the pound sterling value of the exchange tokens at the relevant date.

HMRC does not consider exchange tokens to be currency or money, so they do not meet the definition of 鈥榤oney鈥� for Stamp Duty consideration purposes. They will also generally not count as 鈥榮tock or marketable securities鈥�.

Broadly, 鈥榙ebt鈥� counts as chargeable consideration for Stamp Duty in the following scenarios:

• release of a debt 鈥� The seller has an outstanding debt to the purchaser (which could be in the form of exchange tokens). The seller transfers shares to the purchaser, and in consideration the purchaser releases the seller from the debt.
• debt is assumed 鈥� A third party has an outstanding debt to the purchaser (which could be in the form of exchange tokens). The seller transfers shares to the purchaser, and in consideration the seller is assigned the right to the debt from the third party.