Liability ― shares, other securities and related services

Produced by a Tolley Value Added Tax expert

Value Added Tax

Guidance

This guidance note covers the liability of shares, other securities and related services.

For an overview of liability more broadly, see the Liability ― overview guidance note.

For in-depth commentary on the legislation and case law on the liability of shares, other securities and related services see also De Voil Indirect Tax Service V4.136A.

Issue, transfer and receipt of securities

Legislation exempts from VAT the issue, transfer, receipt of, or any dealing with:

•
any security
•
any secondary security

VATA 1994, Sch 9, Pt II, Group 5, Item 6

The legislation contains a list of what securities and secondary securities are for these purposes and these are set out below in this guidance note. Notably, this list does not contain securities for money. Securities for money are covered by a separate part of the finance exemption and are discussed in the Liability ― money and related services guidance note.

Whilst the legislation exempts ‘the issue’ of securities this is in fact normally not a supply for VAT purposes.

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