Joshua Critchlow

This Practice Note explains the various reliefs from corporation tax available (provided certain requirements are met) upon incorporation of an overseas branch, including relief in respect of chargeable gains and under the intangible fixed assets regime, as well as relief pursuant to the UK legislation that implemented the Mergers Tax Directive.

This Practice Note outlines how a UK tax resident company can migrate from the UK in practice, including by way of direct emigration (by transferring its tax residence overseas) or corporate inversion (by inserting a new non-UK resident top company). This Practice Note also briefly explains how and why a non-UK company might migrate to the UK by becoming UK tax resident. Produced in partnership with Nicholas Gardener of Ashurst.

This Practice Note outlines the UK corporation tax exit charges that can arise as a result of a company’s migration by shifting its tax residence from the UK to another jurisdiction; the circumstances in which such charges can be deferred; and the post-migration UK tax considerations.

This Precedent is a letter notifying HMRC (as required by TMA 1970, s 109B) of a company’s intention to cease to be UK resident and seeking HMRC’s approval of the proposed arrangements for payment of the company’s UK tax liabilities.

This Checklist outlines the points that must be considered when a company is migrating from the UK by shifting its tax residence from the UK to another jurisdiction.