A client acquired some shares in a listed company by virtue of his employment with said overseas company whilst non UK resident.
He then sells this shares when UK resident and faces a UK CGT liability.
I am interpreting three different treatments of the CGT liability.
1. The CGT base cost of the shares is the UK equivalent of the market value when acquired (which would be the treatment of course if he was UK resident when he acquired them)
2. There is no CGT base cost as the shares were acquired when non UK resident. CGT is paid on the full value on disposal.
3. There is no CGT base cost and CGT is paid on the full value on disposal but with a credit for income tax paid overseas on acquisition, such credit being a maximum of 20% of the gain.
(1) seems perfectly logical, (2) seems totally unfair an illogical and (3) seems overly generous. The legislation seems to be unclear on this issue. Does anyone have a view? Thank you.