Proposed changes to the stamp tax share consideration rules

Dominic Stuttaford

Greg Branagan

Speed read

Finance (No.3) Bill 2017-19 includes a new provision which imposes a market value rule for share transactions between connected companies involving listed shares. A new consultation published by HMRC (see bit.ly/2Qq0wq3) seeks input by 30 January 2019 on three further proposals in relation to calculating the taxable consideration for stamp duty and SDRT purposes: (1) an extension to the market value rule to apply to transactions in unlisted shares between connected parties (whether natural or legal persons); (2) changing the definition of ‘consideration’ for stamp duty purposes to refer to ‘money and money’s worth’; and (3) aligning the treatment of contingent, uncertain and unascertainable consideration for stamp duty and SDRT purposes.

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