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Posted Wed, 05 Oct 2022 14:14:19 GMT by A Nelson
I hold shares in a US company. The shares in that company went through a share split which did not affect the total value of my share holding in that company. Am I correct that such share splits with no change in total value are (a) not liable to Capital Gains Tax, (b) not liable to Income Tax? According to: then a share reorganisation which replaces shares by those of equivalent value is not treated as if you’ve sold or disposed of them for Capital Gains Tax purposes. However the article does not comment on Income Tax and does not mention if there is any different treatment of CGT or Income Tax for foreign share holdings.
Posted Wed, 12 Oct 2022 10:28:12 GMT by HMRC Admin 20
Hi Andrew Nelson,

The company may have issued a circular or prospectus to its shareholders (both resident and non resident).
This should include the company’s explanation of the UK tax treatment. 
Generally, for capital gains purposes a share reorganisation is not treated as a disposal of the taxpayer’s existing shares or an acquisition of any new shares and new shares issued are treated as though they were acquired at the same time as the existing shares.
You may need to apportion the allowable cost from the respective values of the shares, see:
 HS285 Share reorganisations, company takeovers and Capital Gains Tax (2022)
There is more on foreign income here:
SAIM1130 - Savings and investment income: foreign income Territorial scope

Thank you.

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