Stamp Duty and Stamp Duty Reserve Tax (SDRT)

Stamp duty and SDRT are not chargeable under stock lending arrangements where securities of the same kind are returned to the lender. The same rule applies to sale and repurchase arrangements as both are characterised as a form of secured lending.

Baker Tilly analysis

The credit crunch has resulted in a number of defaults and agreements being terminated due to the purchaser's insolvency. This is a welcome relieving measure.