HSBC Holdings Plc and The Bank of New York Mellon Corporation v Revenue and Customs: FTTTx 28 Feb 2012

FTTTx SDRT – acquisition of target company as part of which overall transaction shares issued to exchange agent on trust for target’s ex-shareholders and subsequently ADRs issued to target’s ex-shareholders – whether SDRT charge on transfer of shares to issuer of ADRs was unlawful under the Capital Duties Directive and/or the Treaty – no reference to CJEU – appeal allowed

[2012] UKFTT 163 (TC)
Bailii
England and Wales

Stamp Duty

Updated: 01 November 2021; Ref: scu.462584