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Policy Paper Published 29 Nov 2022 HM Revenue & Customs ↗ View on GOV.UK

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.

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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.