Modernisation of Stamp Taxes on Shares Framework

By Technical Team on 28 Jul 2020

On L-Day the government published a call for evidence to consider the principles and design of a new Stamp Duty and SDRT Framework, which is intended to inform a longer-term modernisation of Stamp Duty and SDRT.  The government is seeking views on what should be the principles and design of a new framework for taxing shares and securities and what should be prioritised in any modernisation programme. 

The call for evidence can be found here.

This builds on the work done by the OTS in 2017 and the recent changes around the Shares Consideration Rules which were consulted upon and amended in 2018 and 2019 respectively. The call for evidence notes that in the ‘Stamp taxes on shares: Consideration Rules Summary of Responses’ document published in July 2019 the government acknowledged that the changes made in isolation of wider reform and modernisation of Stamp Duty would cause negative impacts on certain sectors. 

The call for evidence discusses the Stamp Taxes on Shares (STS) framework, which is the legislation, guidance and administrative processes that allow HMRC to administer Stamp Duty and SDRT effectively. This includes obligations on HMRC and taxpayers such as:

  • when and how taxpayers must notify an obligation to pay tax,
  • how liability is calculated and agreed, including determining eligibility for reliefs and exemptions,
  • how tax is collected (for example compliance powers, penalties and interest; and
  • how disputes are managed.

The call for evidence also references the temporary changes that have been made to STS processes in light of COVID-19. 

Please send any comments to technical [at] by Monday 18 September 2020.