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.

Documents

Draft legislation in a PDF format

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Explanatory note in a PDF format

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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.