§ Mr. Ralph Howellasked the Chancellor of the Exchequer what representations he has received about the liability to stamp duty and the stamp duty reserve tax of the units offerred for sale by Eurotunnel.
§ Mr. Norman LamontThe companies, the stock exchange and other interested parties have discussed the offer with the Inland Revenue.
The Eurotunnel group will be offering for sale to the public units comprising one share in Eurotunnel plc and one share in Eurotunnel SA. They will require that these shares are issued and transferred together, as a single unit, in order to link United Kingdom and French participation in the tunnel project. This arrangement would, however, give rise to complex charges to stamp duties and stamp duty reserve tax. The taxes would sometimes apply to the unit and sometimes to the Eurotunnel plc share only. These results were not envisaged when the legislation was introduced, and would complicate dealings in the units. The next Finance Bill will therefore include proposals to make the unit chargeable security for stamp duty and reserve tax purposes, and to remove the initial charge to bearer instrument duty on the issue of units and warrants to acquire units abroad.
844WThe intention of these changes is to treat the units for stamp duty and the reserve tax in the same way as a single share.