Produced by Tolley in association with Anne Fairpo
  • 27 Jun 2022 10:04

The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:

  • Inbound migration
  • Reasons for an inbound migration
  • Consequences of inbound migration

Inbound migration

Reasons for an inbound migration

Migration describes the situation when a company changes its tax residence. A company which is not incorporated in the UK may become resident for tax purposes in the UK if it becomes centrally managed and controlled in the UK.

The Government is currently consulting on whether or not to introduce a corporate re-domiciliation regime. The consultation closed on 7 January 2022 and the response is expected to be published by HMRC in due course.

See the Residence of companies guidance note.

In many cases, this may happen accidentally, but a well-advised company will avoid this by taking appropriate action to ensure that central management and control is kept outside the UK.

However, in some cases, there may be tax benefits of a company becoming resident in the UK, for example:

  1. to take advantage of a UK double tax treaty

  2. to avoid the application of anti-avoidance rules such as the attribution of gains under TCGA 1992, s 3 (formerly TCGA 1992, s 13) ― see the Gains attributable to participators in non-UK resident companies guidance note ― or the transfer of assets abroad rules, see Example 1

  3. to qualify under the subsidiary substantial shareholding exemption (

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