The government has announced that further anti-avoidance measures will be included in the Spring Finance Bill 2023. The following is an extract from the HM Treasury document CP751, entitled Autumn Statement 2022 (para. 5.41), with paragraph spacing added for greater clarity:
“To address tax avoidance, the government will legislate in Spring Finance Bill 2023 so that shares and securities in a non-UK company acquired in exchange for securities in a UK close company will be deemed to be located in the UK.
This will have effect where an individual has a material interest in both the UK and the non-UK company and where the share exchange is carried out on or after 17 November 2022.
Draft legislation and supporting documents will be published alongside the Autumn Statement.”
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