The recent decision of the First-tier Tribunal in HSBC Holdings PLC and The Bank of New York Mellon Corporation v HMRC [2012] UK FTT 163 has held that the Capital Duties Directive prohibits the UK's 1.5% SDRT charge on issues or transfers of shares into an American Depository Receipt (ADR) programme, where that issue or transfer forms an integral part of the raising of capital.
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