Exemption from Stamp Duty and Stamp Duty Reserve Tax (SDRT)

The hybrid capital instruments rules (Para 20 to Schedule 20 Finance Act 2019) provide an exemption from Stamp Duty and SDRT on the transfer of these instruments providing they fall within the meaning of section 475C Corporation Tax Act 2009 (CTA 09).

S. 475C(1) says:

'For the purposes of this Part, a loan relationship is a ‘hybrid capital instrument’ for an accounting period of the debtor if -

a) the loan relationship makes provision under which the debtor is entitled to defer or cancel a payment of interest under the loan relationship,

b) the loan relationship has no other significant equity features, and

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