Client Alert
| January 21, 2010
Overpaid UK Stamp Duty Reserve Tax?
On 15 January 2010, Her Majesty's Revenue & Customs ("HMRC") published an invitation to taxpayers to reclaim tax paid in respect of unlawful charges to stamp duty reserve tax ("SDRT").
This invitation responds to the recent ruling of the European Court of Justice ("ECJ") in HSBC Holdings plc, Vidacos Nominees Ltd v. The Commissioner of HMRC, Case C-569/07 ("HSBC"), that the 1.5 percent "season ticket" SDRT charge on the issue of shares by a UK incorporated company into a clearance system within the European Union is contrary to the EU Capital Duty Directive 69/335/EEC.
For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
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