Under FA 1986, s. 67, there is a charge to stamp duty on an instrument (other than a bearer instrument – for which see ¶400-410) transferring ‘relevant securities’ of a UK-incorporated company to a depositary-receipt scheme, whether or not duty would otherwise be chargeable under FA 1999, Sch. 13, para. 1 on the instrument as effecting a transfer on sale.

‘Relevant securities’ in this connection are shares in, or stock or marketable securities of, any UK-incorporated company (FA 1986, s. 67(1), 69(3)).

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