Important Note—Anti-avoidance rules on use of ‘deep in the money options’
Legislation will be introduced in the Finance Bill 2016 to stop avoidance of stamp duty and stamp duty reserve tax using ‘deep in the money’ options to transfer shares to a depositary receipt issuer or clearance service. Deep in the money call options have a strike price significantly below market value. Shares transferred to a depositary receipt issuer or clearance service