Share cost basis

Split-off of Liberty Global’s Latin America and Caribbean businesses (“LiLAC Group”) 2017

Distribution of Liberty Latin America Class A, Class B and Class C Common Shares

Transaction: On December 29, 2017, Liberty Global plc effected the Split-Off by distributing to holders of its LiLAC Ordinary Shares as a dividend: (i) one Liberty Latin America Class A common share for each Class A LiLAC Ordinary Share, (ii) one Liberty Latin America Class B common share for each Class B LiLAC Ordinary Share, and (iii) one Liberty Latin America Class C common share for each Class C LiLAC Ordinary Share, in each case, held by such shareholder as of the distribution date, in accordance with the Liberty Global plc articles and applicable law. Immediately following the distribution, the LiLAC Ordinary Shares were redesignated as deferred shares (with virtually no economic rights) and those deferred shares were transferred for no consideration to a third-party designee.

December 29, 2017 Basis Allocation – U.S. Tax:

The U.S. Federal tax basis of each Liberty Latin America common share received in the split-off should be the same as the U.S. Federal tax basis of the LiLAC Group share exchanged.

This is not tax advice. Please note that the information above is provided solely as a convenience to shareholders. Liberty Global plc does not provide its shareholders with tax advice and the information above is not intended to provide tax advice. Liberty Global plc encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.

DOWNLOAD FORM 8937 A – PDF
DOWNLOAD FORM 8937 B – PDF
DOWNLOAD FORM 8937 C – PDF

Distribution 2016

Distribution of LiLAC Group Class A, Class B and Class C Ordinary Shares 2016

July 2016

Transaction: On July 1, 2016, holders of our Liberty Global Group Class A, Class B and Class C ordinary shares received a share distribution of 0.124769 share of LiLAC Group Class A, Class B and Class C ordinary share for every one share in each Liberty Global Group Class A, Class B and Class C ordinary share held on the record date (the “Distribution”). The Distribution should be treated as a non-taxable distribution and should not give rise to taxable income to Liberty Global Group shareholders for U.S. federal income tax purposes. However, cash received in lieu of fractional LiLAC Group shares is taxable. Liberty Global plc is organized under the laws of England and Wales and, accordingly, the Distribution constitutes a bonus issue of shares under its articles of association and under UK law (the new shares being paid up by capitalizing profits of US $0.01 per share). We refer to such bonus issue as a “Distribution” for convenience.

July 5, 2016 Trading Activity:

July 5, 2016 Basis Allocation:

* As there was no active trading activity for the LiLAC Group Class B (LILAB) ordinary shares on July 5, 2016, we are only providing an illustration of the basis allocation information regarding the LiLAC Group Class A (LILA) and LiLAC Group Class C (LILAK) ordinary shares. There are several potential methods for determining the fair market values of the LiLAC Group Class B ordinary shares for the purposes of allocating tax basis following the transactions. Please consult your tax advisor regarding the allocation of basis amongst your shares.

This is not tax advice. Liberty Global plc is providing an example of how to allocate a shareholder’s aggregate tax basis in each pre-Distribution Liberty Global Group Class A or Class C ordinary share between such ordinary share and the LiLAC Group Class A and Class C ordinary share received in the Distribution. This example is provided solely for illustrative purposes and as a convenience because shareholders and their tax advisors may find it useful when establishing their specific tax positions. Please remember that Liberty Global plc does not provide its shareholders with tax advice, and this illustrative example is not intended to provide tax advice. Liberty Global plc encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.

Cable & Wireless Communications Acquisition 2016

On May 16, 2016, a scheme of arrangement (“the Acquisition”) became effective under UK law whereby the shareholders of Cable & Wireless Communications plc (“CWC”), transferred all of their CWC shares to Liberty Global plc (“Liberty Global”), in exchange for shares of Liberty Global, which based on each shareholder’s election would consist of:

1. Liberty Global Class A Ordinary Shares and Liberty Global Class C Ordinary Shares (collectively “Liberty Global exchanged shares”),
2. Liberty LiLAC Group (“LiLAC”) Class A Ordinary Shares and LiLAC Class C Ordinary Shares (collectively “LiLAC exchanged shares”), or
3. Both Liberty Global exchanged Shares and LiLAC exchanged shares.

Upon effectiveness of the Acquisition, Liberty Global owned 100 percent of the shares of CWC.

As part of the same plan that includes the Acquisition, CWC will be merged into a wholly-owned subsidiary of Liberty Global (“the Merger”).  It is intended that the Merger will comply with the procedure set out in the UK Companies Cross-Border Mergers Regulations 2007 (SI 2007/2974) and Part 3A of Title 7 of Book 2 of the Dutch Civil Code.  Liberty Global will treat the Acquisition and the Merger as a single, integrated transaction for US federal income tax purposes.

Based upon the facts available, the company believes that, as structured, the exchange by CWC shareholders of CWC shares for Liberty Global exchanged shares, LiLAC exchanged shares, or both, together with the Merger, should be treated as a non-taxable reorganization and should not give rise to taxable income to CWC shareholders for U.S. federal income tax purposes. However, cash received in lieu of fractional Liberty Global exchanged shares and / or LiLAC exchanged shares is taxable.

We have provided a description of the impact on tax basis and supporting data in the attached Form 8937, “Report of Organizational Actions Affecting Basis of Securities”.

This is not tax advice.  Please remember that Liberty Global does not provide its shareholders with tax advice, and for more information regarding the material tax considerations for the transaction, see the public documents referred to in response to Question 19 of the attached Form 8937.  Liberty Global encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.

LiLAC Recapitalization 2015

Distribution of LiLAC Class A, Class B and Class C Ordinary Shares 2015

July 2015

Transaction: On July 1, 2015, holders of our ordinary shares received a share distribution of one-twentieth of a share of LiLAC Class A, Class B and Class C ordinary share for each Liberty Global plc Class A, Class B and Class C ordinary share held on the record date (the “Recapitalization”). The Recapitalization should be treated as a non-taxable reorganization and should not give rise to taxable income to Liberty Global shareholders for U.S. federal income tax purposes. However, cash received in lieu of fractional LiLAC shares is taxable. Liberty Global is organized under the laws of England and Wales and, accordingly, the Recapitalization constitutes a bonus issue of shares under its articles of association and under UK law (the new shares being paid up by capitalizing profits of US $0.01 per share). We refer to such bonus issue as a “Recapitalization” for convenience.

July 2, 2015 Trading Activity:

July 2, 2015 Basis Allocation:

* As there was no trading activity for the LiLAC Class B (LILAB) ordinary shares on July 2, 2015, we are only providing an illustration of the basis allocation information regarding the LiLAC Class A (LILA) and LiLAC Class K (LILAK) ordinary shares. There are several potential methods for determining the fair market values of the LiLAC Class B shares for the purposes of allocating tax basis following the transactions. Please consult your tax advisor regarding the allocation of basis amongst your shares.

This is not tax advice. Liberty Global is providing an example of how to allocate a shareholder’s aggregate tax basis in each pre-Recapitalization Liberty Global Class A, Class B or Class C ordinary share between such ordinary share and the LiLAC Class A, Class B and Class C ordinary share received in the Recapitalization. This example is provided solely for illustrative purposes and as a convenience because shareholders and their tax advisors may find it useful when establishing their specific tax positions. Please remember that Liberty Global does not provide its shareholders with tax advice, and this illustrative example is not intended to provide tax advice. Liberty Global encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.

Liberty Global Group – Dividend 2014

Dividend (or Bonus Issue) of Class C Ordinary Shares 2014

March 2014

Transaction: On March 3, 2014, holders of our ordinary shares received a dividend of one Class C ordinary share for each Class A, Class B and Class C ordinary share held on the record date (the “Dividend”). The Dividend should be treated as a non-taxable share distribution and should not give rise to taxable income to Liberty Global shareholders for U.S. federal income tax purposes. Liberty Global is organized under the laws of England and Wales and, accordingly, the Dividend constitutes a bonus issue of shares under its articles of association and under UK law (the new shares being paid up by capitalizing profits of US $0.01 per share). We refer to such bonus issue as a “dividend” for convenience.

March 4, 2014 Trading Activity:

March 4, 2014 Basis Allocation:

This is not tax advice. Liberty Global is providing an example of how to allocate a shareholder’s aggregate tax basis in each pre-Dividend Liberty Global Class A, Class B or Class C ordinary share between such ordinary share and the Class C ordinary share distributed in the Dividend. This example is provided solely for illustrative purposes and as a convenience because shareholders and their tax advisors may find it useful when establishing their specific tax positions. Please remember that Liberty Global does not provide its shareholders with tax advice, and this illustrative example is not intended to provide tax advice. Liberty Global encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.

Dividend 2014 Q & A

Questions and Answers for Liberty Global plc shareholders

This information is intended to answer questions you may have about our recently announced dividend of Class C ordinary shares. Liberty Global is organized under the laws of England and Wales and, accordingly, the dividend of Class C ordinary shares constitutes a bonus issue of shares under its articles of association and under UK law (the new shares being paid up by capitalizing profits of US$0.01 per share). We refer to such bonus issue as a “dividend” for convenience.

Q: Why has Liberty Global decided to declare a stock dividend of one Class C ordinary share on each outstanding Class A, Class B and Class C ordinary share?

The decision to declare a dividend of one Class C ordinary share on each outstanding Class A, Class B and Class C ordinary share (the “Dividend”) was made by Liberty Global’s Board of Directors based on a desire to provide greater liquidity to holders of our Class C ordinary shares since the float has decreased over the last several years due to our substantial share repurchases and to provide us with greater flexibility in our future M&A activity. Additionally, since our formation in 2005, our stock has significantly outperformed the broader market with significant price increases. The Dividend will reduce the price of each ordinary share beginning on the ex-dividend date and make our ordinary shares more attractive and accessible to a broader range of investors.

Q: What is the effective date of the Dividend?

There are several key dates:

• The record date, February 14, 2014, determines which shareholders are entitled to receive the Dividend.
• The issuance date, March 3, 2014, is the date the Class C ordinary shares will be issued pursuant to the Dividend.
• The ex-dividend date, March 4, 2014, is the date when our Class A, Class B and Class C ordinary shares will trade on NASDAQ at the new Dividend-adjusted price.

Q: How does the Dividend affect my investment in Liberty Global?

As a shareholder of record as of 10:00 p.m. GMT (5:00 p.m. Eastern time) on February 14, 2014, as a result of the Dividend, you will receive additional Class C ordinary shares as of the issuance date on March 3, 2014. For each Class A, Class B and Class C ordinary share you hold on the record date, you will receive one additional Class C ordinary share. For example, if on February 14, 2014, you owned 100 Class A ordinary shares and 100 Class C ordinary shares, you will own 100 Class A ordinary shares and 300 Class C ordinary shares on March 3, 2014. The cost basis of the ordinary shares will be adjusted based on their relative fair market values on the ex-dividend date, which adjustment the company intends to publish to its website as soon as possible after the ex-dividend date.

Q: What are the expected tax consequences of the Dividend?

The Dividend should be treated as a non-taxable share distribution and should not give rise to taxable income to Liberty Global shareholders for U.S. federal income tax purposes. As a non-taxable share distribution, shareholders should allocate their tax basis in each ordinary share of Liberty Global with respect to which the Dividend was made between the pre-Dividend ordinary share and the Class C ordinary share received in the Dividend based on the relative fair market values of such ordinary shares. Liberty Global intends to publish Form 8937 Report of Organizational Actions Affecting Basis of Securities to its website (www.libertyglobal.com) by April 15, 2014, the contents of which will provide further information regarding the taxation of the Dividend and the suggested ratios for shareholders to use in allocating tax basis among their ordinary shares.

For the state and local tax impact of the Dividend and for those shareholders that are subject to tax in a country other than the U.S., we strongly urge such shareholders to consult with their local tax advisor on the tax impacts as they could vary by jurisdiction.

Q: Has Liberty Global declared a dividend of shares or split its stock before?

In September 2005, Liberty Global, Inc., our predecessor, distributed one share of its Series C common stock on each share of its Series A and Series B common stock.

Q: What happens if I sell my Liberty Global ordinary shares after the record date but before the issuance date?

If you sell ordinary shares prior to the record date, you will be selling them at the pre-Dividend price. If you sell ordinary shares after the record date but prior to the issuance date, you will be selling them at the pre-Dividend price and the ordinary shares will trade with a “due bill” (i.e., the ordinary shares you trade are “due” the number of Class C ordinary shares issuable in the Dividend). When you sell your ordinary shares, you surrender your pre-Dividend ordinary shares and any Class C ordinary shares due pursuant to the Dividend.  The due bill is transferred to the new owner of the ordinary shares.

If you buy ordinary shares after the record date but on or before the issuance date, you will purchase the ordinary shares at the pre-Dividend price and will receive a due bill. Following the Dividend, you will receive (or your brokerage account will be credited with) the number of Class C ordinary shares due as a result of the Dividend.

Q: Will there be a “when issued” market for the Class C ordinary shares to be issued in the Dividend?

There will not be a “when issued” market on the NASDAQ Stock Market for the new Class C ordinary shares to be issued in the Dividend.

Q: How will I receive my additional Class C ordinary shares issued in the Dividend?

If you hold shares in certificated form now, you will receive a share certificate. Keep it with your existing share certificates and other important documents as a record of your ownership.

If you hold shares in a brokerage account, the additional shares will automatically be deposited to your brokerage account.

If you hold shares in custody with Computershare US, the additional shares will automatically be deposited to your U.S. custody account.

If you hold shares in the U.K. Corporate Sponsored Nominee (“CSN”), the additional shares will automatically be deposited to your U.K. CSN account.

If you have not yet exchanged your Liberty Global, Inc. or Virgin Media Inc. share certificates for shares in Liberty Global plc, you will receive the additional share(s) at the time of the exchange.

Q: Where will my additional shares or a statement confirmation be mailed?

If you currently hold shares in your name in certificated form, the additional shares will be mailed to your registered address that Computershare Trust Company, N.A., our share transfer agent, has on file. To verify your address you can call Computershare directly – within the U.S. at 888 218 4391 or outside of the U.S. at +1 781 575 3919.

If you hold shares in custody with Computershare US, or in the U.K. CSN, you will receive a statement reflecting the additional shares.

Q: What do I do with my existing Liberty Global ordinary share certificate(s)?

Existing Liberty Global ordinary share certificates are still valid. Do not destroy them. You may deposit your existing certificate(s) in a brokerage account, or you may continue to physically hold them and be responsible for their safekeeping.

Q: How do I request a Liberty Global ordinary share certificate?

We believe custody or a brokerage account is the safest and most convenient way to hold your ordinary shares.

Q: What if I have more questions?

For more information about your Liberty Global shareholder account, please call: (A) your broker (if you hold in a brokerage account); (B) Computershare within the U.S. at 888 218 4391 or outside of the U.S. at +1 781 575 3919 (if you hold a share certificate or your shares are held in custody with Computershare); or (C) Computershare UK at +44 870 702 0000 (if you hold in the U.K. CSN with Computershare).

Liberty Global Group – Virgin Media Transaction 2013

March 7, 2014

Update Tax Treatment Share Exchange

We believe the tax treatment disclosed in the Form 8937 posted to the Liberty Global and the Virgin Media website on July 22, 2013 and disclosed in the Proxy filed on May 1, 2013 still reflects the correct treatment of the transaction for U.S. tax purposes based on determinations of applicable factors during the tax year ended December 31, 2013.

However, investors are cautioned that there are various factual and legal inquiries required for the transaction to be non-taxable to U.S. holders and the relevant rules are complex and new. There can be no assurance that, even if the various factual tests are satisfied, the IRS will not challenge non-taxable treatment of the transaction based upon their view of the legal issues involved or that a court will not agree with the IRS in the event of litigation.

Any discussion regarding the tax treatment related to the transaction is for general purposes only and is not a substitute for a shareholder’s own analysis of the tax considerations related to the transaction. We urge shareholders to consult with their own tax advisor regarding the U.S. (federal, state and local), U.K. and other non-U.S. tax considerations for these matters in light of a shareholder’s particular circumstances.

June 2013

“On June 7, 2013, pursuant to a series of mergers, Liberty Global, Inc. (“Liberty Global”) merged into separate wholly-owned subsidiaries of Liberty Global plc (“New Liberty Global”). In the series of mergers, each outstanding share of common stock of Liberty Global (series A, series B, and series C) was exchanged for a share of the corresponding class (class A, class B, and class C) of ordinary shares of New Liberty Global. The series of mergers are intended to qualify as a reorganization within the meaning of IRC Section 368(a)(1) and the shareholder’s adjusted tax basis in the New Liberty Global shares received in the exchange for the shareholder’s Liberty Global common stock should equal the aggregate adjusted tax basis of the shareholder’s Liberty Global common stock surrendered.

Based upon the facts available to the company and its current projections as of July 22, 2013, the company believes that, as structured, the exchange of Liberty Global common stock for ordinary shares of New Liberty Global pursuant to the mergers may not be taxable to United States (“U.S.”) stockholders of Liberty Global common stock for U.S. federal income tax purposes. However, the tax free treatment for the exchange of Liberty Global common stock for New Liberty Global ordinary shares is not certain and depends on various factual and legal inquiries. The factual determination regarding the tax treatment of the mergers depends, in part, on the calculation of aggregate U.S. shareholder gain and tax basis at the time of the mergers and earnings and profits of post-merger Liberty Global for the 2013 taxable year. This factual determination, therefore, cannot be made until after the end of 2013 and there can be no assurance that the various factual tests will in fact be satisfied. In addition, even if the factual tests are satisfied, there can be no assurance that the U.S. Internal Revenue Service (“IRS”) will not challenge the non-taxable treatment of such exchange based upon their view of the legal issues involved or that a court will not agree with the IRS in the event of litigation.

For more information regarding the material tax considerations for the mergers, see the “The Mergers—Material Tax Considerations for the Mergers—Material U.S. Federal Income Tax Considerations” of the joint proxy statement/prospectus on Schedule 14A of Liberty Global filed with the Securities and Exchange Commission on May 1, 2013. The company will provide updated and additional information relevant to the tax treatment on this website, as it becomes available, including updates to account for 2013 year-end information. Former Liberty Global stockholders are urged to consult with their own tax advisors as to the U.S. federal income tax treatment of the exchange of Liberty Global common stock for New Liberty Global ordinary shares.”

Liberty Global Group – Dividend 2005

September 2005

Transaction: Each share of LGI Series A and Series B Common Stock held on the record date for the distribution will receive 1 share of LGI Series C Common Stock. The transaction is generally intended to be tax-free to holders of LGI Series A and Series B Common Stock for U.S. federal income tax purposes.

September 7, 2005 Trading Activity:

September 7, 2005 Basis Allocation: