Stamp Duty Matrix

Stamp Duty & Financial Transaction Tax Matrix v0.1

What this file is

This file is a content skill that loads on top of cross-border-workflow-base. It covers stamp duties on documents, securities transfers, and the parallel financial transaction tax (FTT) regimes that economically resemble stamp duty.

Tax year coverage. Current for calendar 2025, reflecting:

• UK stamp taxes — SDRT 0.5% on chargeable securities; stamp duty on physical paper transfers; 1.5% SDRT/stamp duty on issuances to clearance services / depositary receipts confirmed by HMRC after the CJEU HSBC ruling
• Italian FTT unchanged at 0.2% (regulated market) / 0.22% (OTC); derivatives schedule
• French FTT at 0.3% on French listed company shares (in-scope > EUR 1bn cap)
• Spanish FTT (IFT) at 0.2% on Spanish listed shares > EUR 1bn cap
• Hong Kong stamp duty on shares reduced 0.10% buyer + 0.10% seller (cut from 0.13% in November 2023)
• Singapore ACD (Additional Conveyance Duty) rules for property-rich entities
• Indian Stamp Act as substantively amended (federal stamp duties on securities since 2020 + state stamp duty on instruments)

The reviewer is the customer of this output. Stamp duty assessments depend on precise document characterisation and jurisdiction. Every output must be reviewed by a credentialed local practitioner before any document is executed.

Section 1 — Scope statement

• Skill coverage — included — Stamp duty on securities (shares, bonds, partnership interests); Stamp duty on instruments (loan agreements, mortgages, leases — to the extent not in property transfer skill); Financial transaction taxes (FTT) — France, Italy, Spain, OTC + listed; Documentary stamp taxes — US state-level documentary stamp taxes, Philippines DST, India state stamp duty; Bank levies and securities account taxes (Belgium TCT, illustrative) (Section 1 — Scope statement)
• Skill coverage — excluded — Real estate transfer tax / stamp duty on property — see property-transfer-tax-matrix.md; VAT/GST on financial services — see country VAT skills; Inheritance/gift documentary tax — see inheritance-estate-gift-matrix.md; Customs duty — see customs/duties skills (Section 1 — Scope statement)

Section 2 — UK Stamp Duty Reserve Tax (SDRT) and Stamp Duty

2.1 SDRT (FA 1986 Part IV)

• [T1] Rate — 0.5% of consideration for the transfer of chargeable securities (FA 1986 Part IV)
• Chargeable securities — UK-incorporated company shares (and similar), some loan notes, units in unit trusts (s.99 FA 1986)
• Trigger — Agreement to transfer (regardless of whether share register is updated) settled through the CREST system → SDRT applied automatically; for off-CREST, payable via Stock Transfer Form + HMRC stamping (FA 1986 Part IV)

2.2 Stamp duty on paper instruments

• [T1] Rate — 0.5% of consideration; minimum stamp GBP 5. Applies when transfer effected by paper instrument (Stock Transfer Form) (FA 1986 Part IV)

2.3 The "1.5% charge" — depositary receipts and clearance services

• [T1] 1.5% charge — 1.5% SDRT (or stamp duty) on issuance to: a "depositary receipt issuer" (most commonly the bank issuing ADRs); a "clearance service" (e.g., DTC for US investors) (FA 1986 ss.67-70 / s.93)
• HMRC post-CJEU HSBC ruling position — Confirmed by HMRC post-2009 CJEU HSBC ruling: the 1.5% on issuance is not generally enforced for EU/EEA destinations (CJEU C-569/07); however, HMRC's position post-Brexit and current administrative practice (FA 2024 amendments) treats issuance into Crest as not subject to 1.5%; complex issue requires specialist review (CJEU C-569/07; FA 2024 amendments)

2.4 Exemptions

• Intra-group relief — 0% for transfers within 75%+ group (s.42 FA 1930 / Sch 19 FA 1999)
• Demergers and reconstructions — Exempt (ss.75-77 FA 1986)
• Loan capital (corporate debt) — Most non-convertible debt exempt (Section 2.4 — Exemptions)
• Shares listed on a recognised growth market — 0% SDRT since 2014 for shares listed on a "recognised growth market" (AIM, AQSE Growth, certain SME markets) (Section 2.4 — Exemptions)

2.5 Filing

• Filing mechanics — CREST: automatic. Off-CREST: file STF with HMRC within 30 days of execution; instrument stamped (Section 2.5 — Filing)

Section 3 — Italy Financial Transaction Tax (FTT)

3.1 Three pillars

Three pillars — Italy FTT (Decreto Legge 24 aprile 2012 n.16)

Pillar	Rate	Base
Tobin tax (cash equities)	0.2% (regulated market) / 0.22% (OTC)	Net daily balance per ISIN per intermediary; Italian-resident issuer share value > EUR 500m cap
Derivatives	EUR 0.01875 to EUR 200 per contract (sliding scale by notional value)	Derivatives on FTT-in-scope underlyings
High frequency trading	0.02% on cancelled / modified orders	Orders cancelled within 0.5 seconds, > 60% modify-cancel ratio

3.2 In-scope securities

• In-scope securities — Shares of Italian companies with EUR > 500m market cap; securitised products (ETF) on Italian shares; derivatives referencing Italian shares (Section 3.2 — In-scope securities)

3.3 Exemptions

• Exemptions — Market making activities; pension funds and EU-equivalent retirement vehicles; sovereign wealth funds / central banks; ETF creation / redemption (in-kind); inheritance and gift transfers (Section 3.3 — Exemptions)

3.4 Filing

• Filing mechanics — Italian intermediary acts as withholding agent; monthly remittance Model F24; annual reporting to Agenzia delle Entrate (Section 3.4 — Filing)

Section 4 — France FTT

4.1 Three components

Three components — France FTT (CGI Articles 235 ter ZD - ZE)

Component	Rate	Base
Tax on equity acquisitions	0.3%	Acquisitions of French-listed shares of EUR 1bn+ market cap issuers
Tax on HFT cancellations	0.01%	Orders modified or cancelled within 0.5 seconds
Tax on sovereign CDS	0.01%	Naked sovereign credit default swap purchases

4.2 Scope

• Scope — French-incorporated companies listed on regulated EU market with market cap > EUR 1bn on 1 December prior year; maintained list published annually by Ministry of Finance (~140 issuers) (Section 4.2 — Scope)

4.3 Exemptions

• Exemptions — Primary market issuances; liquidity provision / market making; intra-group transfers; acquisitions by employee schemes (Section 4.3 — Exemptions)

4.4 Filing

• Filing mechanics — Withheld by accountable person (Euroclear France or intermediary); returned via Form 3375 monthly (Section 4.4 — Filing)

Section 5 — Spain FTT (IFT — Impuesto sobre las Transacciones Financieras)

5.1 Mechanics (Ley 5/2020)

• [T1] Rate — 0.2% (Ley 5/2020)
• Scope — Acquisitions of Spanish-listed shares of EUR 1bn+ market cap issuers (annually published list) (Ley 5/2020)
• Liable party — The financial intermediary (Ley 5/2020)
• Exclusions — Primary market issuance, intra-group transfers, market making (Ley 5/2020)

5.2 Filing

• Filing mechanics — Monthly Form 604 (Section 5.2 — Filing)

Section 6 — Other European stamp / FTT

Other European stamp / FTT (Section 6 — Other European stamp / FTT)

Country	Mechanism	Rate
Ireland	Stamp duty on share transfers	1% on Irish shares (FA 1999 Sch 1)
Ireland	Stamp duty on residential property	1% / 2% / 10% (see property skill)
Switzerland	Stamp duties on securities (Umsatzabgabe)	0.15% Swiss securities / 0.30% non-Swiss (per dealer)
Switzerland	Issuance stamp duty (Emissionsabgabe)	1% above CHF 1m on equity issuance (planned abolition); 0.06%-0.12% on certain debt
Liechtenstein	Mirrors Swiss stamps for shares	Same Swiss rates
Luxembourg	Registration duty on certain documents	Variable; capital duty long abolished
Belgium	Securities Transactions Tax (TOB)	0.12% / 0.35% / 1.32% by category
Belgium	Securities Account Tax (TCT)	0.15% above EUR 1m per account
Greece	Stamp duty on certain agreements	2.4% or 3.6%
Cyprus	Stamp duty on transactions of capital value > EUR 5,000	0.15% on EUR 5,001 - 170,000; 0.20% above
Malta	Stamp duty on share transfers	2% (5% if real-estate-rich entity)
Portugal	Imposto do Selo on financial transactions, leases, loans, insurance, guarantees	0.04%-25% by category
Norway	Document duty (real-property only)	2.5% (see property skill)
Sweden, Finland, Denmark	No stamp duty on shares / FTT

Section 7 — Asia-Pacific

Asia-Pacific stamp / FTT (Section 7 — Asia-Pacific)

Country	Mechanism	Rate
Hong Kong	Stamp duty on share transfers	0.10% buyer + 0.10% seller (reduced from 0.13%, November 2023)
Singapore	Stamp duty on share transfers	0.2% of consideration (BSD subset for share transfers; ACD applies for residential property-rich entities)
Singapore — ACD	Additional conveyance duty	Up to 65% on acquisition of significant equity interests in property-rich entities
Australia	Stamp duty on share transfers	Abolished federally 2002; state-level mostly abolished for shares but landholder/property-rich rules apply (each state)
New Zealand	No stamp duty on shares	n/a
India	Indian Stamp Act (federal stamp on securities since 2020; state stamp on instruments)	0.005% on equity issuance and transfer; 0.015% on equity delivery-based; state-specific for other instruments
Japan	Stamp duty on contracts and securities	Document-based (Stamp Tax Law, fixed amounts by document type); no FTT on share transfers
South Korea	Securities Transaction Tax	0.15% to 0.35% by market (reduced from previous 0.43%)
China	Securities Transaction Stamp Tax	0.1% one-sided (sale only since 2008 reform) on A-shares; reduced to 0.05% temporarily in August 2023
Taiwan	Securities Transaction Tax	0.3% on equities; 0.1% on bonds (mostly exempt)
Indonesia	No FTT on shares; small documentary stamp	n/a
Thailand	Stamp duty on instruments	Fixed amounts by document type; share transfer 0.1%
Philippines	Documentary Stamp Tax (DST)	Wide-ranging, see NIRC §173-201
Malaysia	Stamp duty on share transfers	0.3% on physical shares; 0% on shares of public listed companies traded on Bursa Malaysia (FA 2023)
Vietnam	Securities Transaction Tax	0.1% on sale

Section 8 — Americas

Americas stamp / FTT (Section 8 — Americas)

Country	Mechanism	Rate
United States — Federal	No federal stamp on shares; SEC Section 31 fee (~0.00229%) levied on equity transactions	n/a
United States — State	New York stock transfer tax in force but 100% rebate has applied since 1981 (effectively 0% federal-state); Florida documentary stamp on stock = 35 cents per USD 100; other state DSTs by document	Varies
Canada	No federal or provincial stamp duty on shares	n/a (subject to LTT in QC for certain documents)
Mexico	Impuesto sobre Adquisición de Inmuebles ("ISAI") and Impuesto a la Adquisición de Acciones ("if applicable")	n/a as general FTT — primarily local property
Brazil — IOF on securities (IOF/títulos)	Tax on securities transactions	0% to 1.5% depending on issuer / holding period / instrument; complex matrix
Argentina — Impuesto de Sellos	Provincial stamp duty	0.5%-3% on contracts (mostly real estate, leases, loans) — varies by province
Chile — Impuesto de Timbres y Estampillas	Stamp tax on loans and other documents	0.066% per month (capped at 0.8%) on loan amount
Colombia — Impuesto de Timbre	Stamp tax	Specific rates by document; reformed 2022
Peru — Impuesto a las Transacciones Financieras (ITF)	Tax on bank account movements	0.005% per debit/credit on local bank accounts

Section 9 — Africa and Middle East

Africa and Middle East stamp / FTT (Section 9 — Africa and Middle East)

Country	Mechanism	Rate
South Africa	Securities Transfer Tax (STT)	0.25% on share transfers and beneficial ownership changes
Egypt	Stamp tax on securities transactions	0.05% per side for tax residents (0.15% on disposal for non-residents)
Nigeria	Stamp duty on instruments	0.075% on share transfer; 1.5% on documentary purchases above NGN 10k
Kenya	Stamp duty on shares	1% on transfer; 0% on listed transfers since 2006
UAE	No general stamp duty	n/a (sector-specific fees apply)
Saudi Arabia	No general stamp duty	n/a (5% real estate transaction tax separately)
Bahrain	No stamp duty	n/a
Qatar	No stamp duty	n/a
Israel	Stamp duty abolished 2006	n/a

Section 10 — Computation walk-through

Example 1 — UK share acquisition

A UK private equity fund acquires GBP 50m of shares in a UK-incorporated AIM-listed company via CREST.

• AIM exemption applies → 0% SDRT on the AIM portion
• Confirm AIM listing on relevant Recognised Growth Markets list as published by HMRC

Example 2 — Italian listed share — non-resident purchaser

A French institutional buyer purchases EUR 10m of shares in Generali (Italy-listed, > EUR 500m market cap).

• Italian FTT: 0.2% × EUR 10m = EUR 20,000
• Italian intermediary remits; non-resident bears the cost

Example 3 — Hong Kong share transfer

HKD 100m share transfer in a Hong Kong-incorporated private company.

• Buyer side: 0.10% × HKD 100m = HKD 100,000
• Seller side: 0.10% × HKD 100m = HKD 100,000
• Both parties pay; intermediated through IRD stamping

Example 4 — Singapore share-acquisition with property-rich target

Foreign investor acquires 100% of a Singapore Pte Ltd whose >50% of total tangible assets is Singapore residential property.

• Basic transfer stamp duty: 0.2% × consideration
• ACD: applies to "significant owner" (≥50% of qualifying equity interest) acquisitions of "property-holding entities"; up to 65% total when combined with the underlying property's ABSD rates
• Specialist advice required; reviewer escalation

Section 11 — Output specification

The reviewer brief must include:

1. Transaction classification — document type, instrument, security, financial transaction
2. Stamp / FTT analysis per applicable jurisdiction
3. Rate and base with statutory citation
4. Exemption analysis — intra-group relief, market making, primary issuance, listed status
5. Liable party (buyer / seller / both / intermediary withholding)
6. Filing mechanics — when, how, by whom
7. Reviewer questions — open items flagged as [T2] or [T3]

Section 12 — Self-checks

• Document characterisation tested per local taxonomy (each country has distinct "instruments" list)
• Each transaction party's stamp duty position computed separately (buyer vs seller)
• Intra-group relief documentary requirements confirmed (75% common ownership for UK)
• AIM / recognised growth market exemption (UK) confirmed against current list
• French / Italian / Spanish FTT scope confirmed against current annual list
• Hong Kong rate (0.10% per side; 0.13% old rate not applied post-November 2023)
• Singapore ACD tested for property-rich entity transfers
• India federal + state stamp duty stacked correctly
• Brazil IOF / Argentina sellos / Chile timbres per applicable transaction type
• Output flags every [T2]/[T3] item for reviewer judgement

Section 13 — Prohibitions

• Prohibitions list — - Do not apply the old 0.13% Hong Kong stamp duty rate to transactions executed after November 2023 — the rate is 0.10% per side. - Do not assume UK intra-group relief applies without confirming 75% common beneficial ownership AND the relief application has been correctly notified. - Do not advise that AIM-listed shares are exempt without confirming the listing is on a HMRC-recognised growth market. - Do not ignore Italian / French / Spanish FTT for non-resident purchasers — the tax is at the security level, not the purchaser's residence. - Do not apply property-rich entity rules (Singapore ACD, Australian landholder duty) without confirming the threshold (typically 50% of tangible assets) and qualifying equity interest tests. (Section 13 — Prohibitions)

Section 14 — Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Stamp duty depends on precise document characterisation and is jurisdiction-specific. Every output must be reviewed and signed off by a credentialed local practitioner before any document is executed.

The most up-to-date, verified version of this skill is maintained at openaccountants.com.