Policy paper

Capital Gains Tax: Share for Share Exchange

This measure makes changes so that non-domiciled individuals pay tax on value built up on UK company securities in the UK, even when those securities are exchanged for securities in an offshore holding company.

From:
HM Revenue & Customs
Published
17 November 2022
Last updated
29 November 2022 — See all updates

Documents

Capital Gains Tax Share Exchange

HTML

Draft legislation

HTML

Draft legislation in a PDF format

PDF, 88.8 KB, 4 pages

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Explanatory Note

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Explanatory note in a PDF format

PDF, 541 KB, 3 pages

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Details

The measure deems shares and securities in a non-UK company received in exchange for share or securities in a UK company to be located in the UK for the purpose of Capital Gains Tax.

Non-domiciled individuals will now pay tax on gains or income received from the shares or securities in the non-UK company, in the same way as if they were in a UK company.

Published 17 November 2022
Last updated 29 November 2022 + show all updates

  1. The Capital Gains Tax share exchange draft legislation HTML version has been updated to bring it in line with the PDF version.

  2. First published.

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