Revenue publishes guidance on the new market capitalisation stamp duty exemption

Revenue has issued guidance outlining the new stamp duty exemption on acquisitions of stocks and marketable securities provided for by Finance Act 2025. The note outlines the conditions applying to the exemption, details on making a valid notification and several illustrative examples. The exemption will apply to a transfer of relevant securities executed between 1 January 2026 and 31 December 2030, where the qualifying conditions are met.

A transfer of relevant securities will qualify for the exemption where:

• At the date of execution of the transfer, the securities are admitted to trading on a regulated market or a multilateral trading facility within the EU, or on an equivalent third country market,
• the issuing entity’s closing market capitalisation was less than €1 billion on 1 December in the preceding year, and
• the transfer is executed during an exemption period, the start and end dates of which are determined by when a valid notification in respect of the market capitalisation was made to Revenue.

Where securities are admitted to trading after 1 December of the previous year, the exemption may still apply if the issuer’s expected market capitalisation upon admission was under €1 billion.