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Impacts of extending the market value rule and aligning the Stamp Duty and Stamp Duty Reserve Tax (SDRT) consideration rules.
HMRC is consulting on a general connected party market value rule for transfers of securities and aligning the definitions of consideration for stamp duty and SDRT.
There are three elements to the consultation:
- extending the market value rule, introduced in Finance Bill 2018-19, to unlisted securities and connected party transfers other than to companies;
- aligning the stamp duty and SDRT definitions of consideration by adopting the SDRT ‘money or money’s worth’ definition.
- aligning the stamp duty and SDRT treatment of contingent, uncertain and unascertainable payments, and the most practical way of doing so.
The market value rule will not be extended to transfers between unconnected parties.
Responses should be emailed to sts.consultation@hmrc.gsi.gov.uk by 30 January 2019.
