What follows must be read in the light of the judgments of the Court of Justice of the European Union in HSBC Holdings plc and Vidacos Nominees Ltd v R&C Commrs (Case C-569-07) [2010] BTC 13 and Air Berlin plc v R & C Commrs (Case C-573/16) [2017] BTC 31 (for both of which see ¶500-320), which countermand the imposition of the ‘entry charge’ to SDRT (and stamp duty) on the issue or transfer of shares into a clearance service in many cases.

What follows makes reference to SDRT only. The identical provisions apply to stamp duty, for which see ¶400-300.

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