Revenue Note for Guidance

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Revenue Note for Guidance

Section 9 Mode of calculating ad valorem duty in certain cases

It may happen that the amount on which stamp duty is chargeable is expressed in a foreign currency e.g. the consideration for a foreign property may be expressed in the currency of the country in which the property is located. This section sets out how that foreign currency amount is to converted into €’s. It provides that where the consideration is in a foreign currency the rate of exchange to be used to convert that currency into its € equivalent is the rate applicable at the date of execution of the instrument.

Example

A buys shares in B Ltd for US$50,500. The transfer is executed on 28 January, 2004. A wants to pay his stamp duty liability in €’s. The duty is calculated as follows:

Euro/US exchange rate on 28/01/04

€1 = US$1.2550

Consideration in US$

US$50,500

Euro equivalent of US$ consideration

€40,239.04 (50,500 ÷ 1.2550)

Duty payable

€402 (i.e. 1% rounded down to the

nearest €).

Relevant Date: Finance Act 2014