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23.09.2026

United Kingdom: New UK Securities Transfer Tax (STT) – Simpler in law, harder in practice

Author
Ali Kazimi
Managing Director
United Kingdom | WTS Hansuke, United Kingdom
View Profile

The UK is planning to replace stamp duty and stamp duty reserve tax (SDRT) on UK share transfers with a single Securities Transfer Tax (“STT”) from 2027. The reform is intended as a modernisation rather than a revenue-raising measure: the main 0.5% charge and the 1.5% higher-rate charge for certain transfers to clearance services or depositary receipt issuers are broadly retained. Draft legislation is expected to be included in the upcoming Finance Bill. The revised rules could be applicable from 1 January 2027.

What changes?

The envisaged regime consolidates the existing rules into a single statutory framework. Chargeable securities will broadly include shares and equity-like debt interests in UK-incorporated companies, units in certain unit trusts and related rights and interests. Existing reliefs for recognised intermediaries, certain fund transactions, in specie redemptions and fund reconstructions are largely preserved, but are expressed directly in the new legislation.

Importantly, historic stamp duty and SDRT practice will not automatically carry over. The draft rules expressly provide that STT is not to be treated as a re-enactment of subordinate legislation under the old regimes. Existing approaches therefore need to be tested against the new statutory wording.

Operational impact for financial institutions

The most significant change is administrative. STT moves transfer tax further into a formal self-assessment and reporting framework. Returns will generally be required for electronic transactions and other relevant transactions unless an exemption applies that does not need to be claimed. Electronic transactions must generally be filed and paid within 14 days, while other transactions are subject to a 30-day deadline.

This places greater responsibility on buyers, accountable persons and agents and will require changes across CREST, registrars, custodians and other market participants. Companies will also be restricted from registering transfers without HMRC acknowledgement of a return or confirmation that no return was required.

What should market participants do now?

Financial institutions should map where STT arises across trading, custody, corporate actions and fund administration, review eligibility for intermediary and other reliefs, and identify who will be responsible for filing, payment and documentation. Existing systems and controls should also be tested to ensure that the new requirements can be handled at scale. The technical consultation on the draft legislation runs until 7 September 2026.

The key message is that the legal framework may become simpler, while implementation may become more demanding. For many institutions, STT should therefore be treated not only as a tax project, but as an operational and technology project ahead of 2027.

Author
Ali Kazimi
Managing Director
United Kingdom | WTS Hansuke, United Kingdom
View Profile
Further information about WTS Hansuke
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