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SDRT: HMRC will not appeal against decision in HSBC

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HMRC has announced that it will not seek permission to appeal against the decision of the First-tier Tribunal in HSBC Holdings PLC and The Bank of New York Mellon Corporation v HMRC [2012] UK FTT 163.

The tribunal decided that that the Capital Duties Directive prohibits the UK's 1.5% SDRT charge on issues or transfers of shares into an American depository receipt programme, where that issue or transfer forms an integral part of the raising of capital.

HMRC has set out in a technical note its view of the implications of the decision.