REVENUE RULING NO. SD 240
ENDORSEMENT OF PROMISSORY NOTES LIABILITY TO STAMP DUTY
1. A question has arisen as to whether section 65 of the Stamp Duties Act applies to the
endorsement of a promissory note.
2. The issue raised for consideration was whether the endorsement of a promissory note by the
payee in favour of a third person renders the promissory note or the transaction evidenced by the
endorsement dutiable as a conveyance under the provisions of the Act.
3. Section 65 defines the expression "conveyance" as including any instrument whereby any
property in New South Wales is transferred to or vested in or accrues to any person.
4. For the purposes of the Stamp Duties Act, the endorsement of a promissory note is not
considered to be an instrument whereby property is conveyed. Accordingly, the endorsement
does not render the promissory note liable to duty as a conveyance as defined in section 65.
5. The provisions contained in Division 3A of the Act seek to impose ad valorem duty on certain
transactions not effected or evidenced by a dutiable instrument. The transaction evidenced by the
endorsement of a promissory note does not come within these provisions.
6. Accordingly, the endorsement of a promissory note is not dutiable under the Stamp Duties Act.
for CHIEF COMMISSIONER OF STAMP DUTIES
8 July 1993.
Last Updated: 17Jan2001