Amendments to Part II of the Schedule
regulation 12(4) of The Stamp Duty Reserve Tax (Amendment) Regulations 1997
- Status not determined
- Mixed — some elements strict, some not
- Tax, customs and excise
This offence was read from the text as made, and no revised version was available, so a later revocation could not be ruled out. Check the current text at legislation.gov.uk.
What the provision says
4 For subsection (1) of section 95 (as modified) there shall be substituted the following subsection— 1 Where a person fraudulently or negligently— a gives any incorrect notice under regulation 4 or 4A of the Stamp Duty Reserve Tax Regulations 1986, or b makes any incorrect statement or declaration in, or in connection with, any claim in respect of stamp duty reserve tax, he shall be liable to a penalty not exceeding the amount of the difference specified in subsection (2) below.
Text as made, from legislation.gov.uk. © Crown copyright, reused under the Open Government Licence v3.0. This is the text as originally made; later amendments are not shown here.
Who it binds, and what has to be proved
- Binds
- a person
- Conduct
- breaching the provision
- Fault element
- Mixed — some elements strict, some not
- Burden of proof
- No statutory defence — prosecution proves everything
The prosecution must prove the conduct, and - for those elements the provision qualifies (fraudulently) - the state of mind it names. The remaining elements carry no fault requirement, so they are strict.
The provision states no defence, so the prosecution bears the burden on every element of the offence.
Classifier’s reasoning: both a mens rea word and an objective standard appear in the offence itself.
What would breach regulation 12(4)?
These are illustrations, not law. They are generated from the provision’s own words to show the shape of the offence. Whether any particular conduct is caught depends on the full text, on any amendment since, and on the facts.
- Doing what the provision prohibits, or failing to do what it requires under the Stamp Duty Reserve Tax (Amendment) Regulations 1997.
Penalty
- Mode of trial
- Not determined
- Maximum fine
- £100
- Maximum prison (summary)
- Not determined
Sentencing
Offences of this kind are usually sentenced under the guidelines below. This is a mapping by subject, not a finding about this provision, and the links go to a search of the Sentencing Council’s own site.
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Fraud, bribery and money laundering offences: definitive guideline
Magistrates' courts and the Crown Court in England and Wales · in force from 1 October 2014
Covers fraud, false accounting, bribery and money laundering, including offences committed by organisations.
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Reduction in sentence for a guilty plea: definitive guideline
All courts in England and Wales · in force from 1 June 2017
The sliding scale of credit for pleading guilty, from one third at the first stage of proceedings downwards.
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General guideline: overarching principles
All courts in England and Wales · in force from 1 October 2019
The guideline a court uses when there is no offence-specific guideline, which is the position for the overwhelming majority of offences created by statutory instrument. It sets out how culpability and harm are assessed from first principles.
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Totality: definitive guideline
All courts in England and Wales
How to sentence more than one offence at once so that the total is just and proportionate - frequently in point here, because regulatory prosecutions commonly charge several breaches of the same instrument.
Prosecution figures
No published per-offence figure was found for this provision, and it could not be matched to a Ministry of Justice offence code. Offences created by statutory instrument very largely do not have one. Absence of a figure is not evidence that the offence is unused.
Status and lifecycle
- Current status
- Status not determined
- Made
- 8 October 1997
- In force from
- 20 October 1997
- Extent
- Not stated
How this was established: read from the text as made; no revised version available, so later revocation could not be ruled out.
What the instrument is for
(This note is not part of the Regulations) — the explanatory note published with the instrument, © Crown copyright.
These Regulations amend the Stamp Duty Reserve Tax Regulations 1986 (S.I. 1986/1711) (“the principal Regulations”). Apart from an amendment of a drafting nature, the amendments reflect recent developments in market structure in connection with share transfers on investment exchanges. The amendments also reflect the introduction of an alternative system of share transfers known as CREST, by means of which the transfer is effected electronically rather than by a paper document. The amendments ensure that the operator of CREST or a similar electronic system, and the operator of a recognised investment exchange or EEA regulated market of which a party to an electronic transfer is a member, is liable to collect and pay stamp duty reserve tax (“SDRT”) incurred in connection with chargeable transactions. Regulation 1 provides for citation, commencement and effect, and regulation 2 for interpretation. Regulation 3 amends existing, and inserts new, definitions (including a definition of “operator”) in regulation 2 of the principal Regulations. Regulation 4 amends regulation 4(1) of the principal Regulations (liability of “accountable person”) in consequence of the new regulation 4A inserted by regulation 5. Regulation 5 inserts a new regulation 4A in the principal Regulations relating to the accountability for SDRT of the operator of an electronic share transfer system or of a recognised investment exchange or EEA regulated market (“the operator”). Regulations 6, 7, 9 and 10 amend regulations 6, 7, 13 and 15 of the principal Regulations in consequence of the accountability for SDRT of the operator. Regulation 8 makes an amendment of a drafting nature to regulation 8 of the principal Regulations. Regulations 11 and 12 amend sections 25, 93, 95, 98 and 99 of the Taxes Management Act 1970 in consequence of the accountability for SDRT of the operator.
Read the full note and every offence in this instrument
Other offences in the same instrument
- For the words “to (4)” substitute “and (3)”; and for the words from “if” to the end substitute “if the…regulation 11(4)
- The taxpayer shall be liable to a penalty which shall be £100regulation 12(3)
- Without prejudice to any penalties under subsections (2) and (3) above, if the failure by the taxpayer to…regulation 12(3)
How this was identified as an offence
Everything above rests on the judgement that this provision creates a criminal offence, rather than mentioning one. That judgement is made by rule, from the words of the provision, and this is the rule that made it — with a confidence of 0.68.
- Basis
- the provision states a penalty in older drafting
- Confidence
- 0.68 of 1.00
A provision that states a penalty for an offence created elsewhere can read very like one that creates an offence, and the rules can mistake the one for the other. If the text quoted above sets a penalty for something made an offence by another provision, treat the classification on this page with that in mind, and read the instrument.
Check the source
- This provision on legislation.gov.uk The authoritative text. Check it before relying on anything here.
- The Stamp Duty Reserve Tax (Amendment) Regulations 1997 Every offence this instrument creates, and its explanatory note
- Tax, customs and exciseOther offences on the same subject
- Offences created in 1997