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Stamp duty exemption for small‑cap securities under Section 86B

Section 86B exempts stamp duty on transfers of stocks listed on a relevant market when the issuer’s market capitalisation is under €1 billion, affecting companies and investors in small‑cap securities.

By Irish Fintax

Revenue has updated guidance on the stamp duty exemption for marketable securities under Section 86B. The exemption applies where the issuing company’s market capitalisation stays below a set threshold at a specific date.

The eBrief also clarifies how to notify Revenue when a company has multiple International Securities Identification Numbers (ISINs).

When the exemption applies

Section 86B provides an exemption from stamp duty on a conveyance or transfer of stocks or marketable securities if the securities are admitted to trading on a “relevant market” and the closing market capitalisation of the issuing company was below €1 billion on 1 December in the previous year.

If the securities were admitted to trading after 1 December in the previous year, the exemption applies where the expected market capitalisation is below €1 billion.

Notification requirements

The Tax and Duty Manual – Section 86B – Market capitalisation has been updated in paragraph 3. The update gives guidance on submitting a valid notification when a company holds more than one International Securities Identification Number (ISIN).

Impact on companies and investors

Companies whose market capitalisation stays under €1 billion can benefit from the stamp duty exemption when their securities are transferred on a relevant market. Investors acquiring such securities will not incur stamp duty on the transaction.

The new notification guidance helps ensure that companies with multiple ISINs can correctly claim the exemption.

Sources

Information provided courtesy of the Revenue Commissioners under a Creative Commons Attribution 4.0 International (CC BY 4.0) licence.

Drafted with the help of AI from the official sources above, then checked and edited by a person before publishing.

General information only, not financial, tax or legal advice. Rates and rules change and your own situation matters, so check with Revenue or a qualified, regulated adviser before acting on a big decision.

Reviewed by Arif Bhuiyan, FCA, ACA, MBA, MSc, and a group of Ireland-based finance professionals who want to make financial literacy easier for people in Ireland.

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