HMRC’s consultation on the modernisation of stamp taxes on shares sets the scene for the introduction of a consolidated single stamp tax, which together with its proposed simplified territorial scope and modern self-reporting portal, represents a fundamental (and largely welcome) change to the UK tax system. However, a number of existing issues appear to remain unresolved, such as a lack of clarity over ‘stock’ for the purposes of acquisition relief, the availability of group relief where foreign entities are involved, and what is ‘reasonably comparable’ for the purposes of the loan capital exemption. The proposed new regime also raises some fresh practical issues, including some uncertainty where contingent and variable consideration is involved and additional compliance burden for small transactions.
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HMRC’s consultation on the modernisation of stamp taxes on shares sets the scene for the introduction of a consolidated single stamp tax, which together with its proposed simplified territorial scope and modern self-reporting portal, represents a fundamental (and largely welcome) change to the UK tax system. However, a number of existing issues appear to remain unresolved, such as a lack of clarity over ‘stock’ for the purposes of acquisition relief, the availability of group relief where foreign entities are involved, and what is ‘reasonably comparable’ for the purposes of the loan capital exemption. The proposed new regime also raises some fresh practical issues, including some uncertainty where contingent and variable consideration is involved and additional compliance burden for small transactions.
If you are not a subscriber, subscribe now to read this content.
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