Assume that you work for a company in the UK that grants you a number of RSUs to vest in a multi-year schedule (as per usual), for example, a vest event every 6 months for 2 years. The RSUs are valued in USD and the company is NASDAQ listed.

At the end of the 2 years, you sell a portion of those RSUs, which have accrued some capital gain.

I want to figure out how to calculate CGT.


  • Do "Section 104 holding" (i.e. each share in the holding is treated as if acquired at the same average cost) rules apply? If they do, should the pool contain all vested shares?

  • If the above is true, to calculate the pooled cost, do you use the USD/GBP exchange rate on the day of the vest, per vest event? If not, what exchange rate do you use?

  • I am assuming that even you don't pay anything for an RSU, the cost to be used is the actual market value on the vest day, per vest event, as if you have paid that from your pocket for CGT purposes. Is this accurate?

  • The disposal proceeds, are those the total value at sale minus fees? If not, what else? As for the exchange rate, do you use for this the one on the day of the sale?


I used information and terminology from this Government website

  • Is this from your employer ? If yes why don't you contact the finance department of your employer ?
    – DumbCoder
    Commented Apr 24, 2018 at 8:07
  • do you mean RSU's and you say a company in the UK do you mean UK company or a US domiciled one who does business in the UK - basicly where are your shares listed ? Commented Apr 26, 2018 at 20:19
  • Also I think the link is for UK Listed companies Commented Apr 26, 2018 at 20:20
  • 1- Yes, it is from my employer. I might contact finance but thought that this could help others. 2- Yes, I mean RSUs, sorry. NASDAQ listed company (hence my interest in the exchange rate) 3- I'm not sure, but did you see evidence this wouldn't apply to everyone?
    – Román
    Commented Apr 27, 2018 at 21:03


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