HM Revenue & Customs has issued a statement outlining a change of practice in relation to stamp duty on a repurchase of shares that are registered on an overseas branch register.
When a company repurchases its own shares, the Companies House return is chargeable with stamp duty at a rate of 0.5% of the consideration. Previously, HMRC had taken the view that this rule also applied when a company repurchased shares registered on an overseas branch register. However, this view has changed and it is now considered that a company’s purchase of its own shares held on an overseas branch register is relieved from stamp duty by section 133 of the Companies Act 2006.
The HMRC statement is available at http://www.hmrc.gov.uk/so/co-purchase-shares-overseas.htm
