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HSBC made a public offer to acquire the shares in Credit Commercial de France a company incorporated and resident in France.
The offer included a share exchange alternative for which HSBC had to obtain a listing on the Paris Stock Exchange.
As a result HSBC had to have an account opened in its name in the French settlement system (Sicovam). The bank agreed to pay any stamp duty reserve tax on shares traded through Sicovam although strictly it was Sicovam’s liability.
The HSBC shares were chargeable securities within the meaning of FA 1986 s 99(3). Where they were issued to a clearance service - i.e. Vidacos Nominees Ltd (Sicovam’s nominee for the UK) - SDRT was payable at 1.5% on the price of the shares under s 96(1) and
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