Loan capital exemption from stamp duty


Published by a ½Û×ÓÊÓƵ Tax expert
Practice notes

Loan capital exemption from stamp duty


Published by a ½Û×ÓÊÓƵ Tax expert

Practice notes
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FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Following the call for evidence in 2020, the resulting outcome published in 2021, consideration by the relevant HMRC and industry working group and the 2023 consultation, the government confirmed in the consultation outcome published on 28 April 2025 that, in 2027, it intends to replace Stamp duty and SDRT with a single self-assessed stamp tax on securities, generally in accordance with the proposals outlined in the 2023 consultation document. Additionally, the government is consulting on modernising and clarifying the legislation imposing the higher rate 1.5% stamp tax charge. For more information, see News Analysis articles: Tax update spring 2025—Stamp taxes on shares modernisation, Tax update spring 2025—Tax analysis—Stamp and transfer taxes, TAMD 2023—Stamp taxes on shares modernisation, TAMD 2023—consultation—stamp taxes on shares and Tax Administration and Maintenance Day—27 April 2023—Stamp and transfer taxes.

Debt which:

  1. •

    qualifies as loan capital (whether it is short or Long-term debt), and

  2. •

    satisfies further conditions aimed at ensuring that it is a normal commercial loan (although certain types

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Stamp duty definition
What does Stamp duty mean?

A transfer tax payable on documents and instruments, rather than in respect of a transaction. It is most commonly encountered on the transfer of UK certificated shares, where the stock transfer form is the instrument that is stamped.

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