Outbound migration

Produced by Tolley in association with Anne Fairpo

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

  • Outbound migration
  • Reasons for an outbound migration
  • Methods of outbound migration
  • Company incorporated in the UK with no double tax treaty in place between the UK and the other country
  • Company incorporated in the UK and double tax treaty is in place between the UK and the other country
  • Company not incorporated in the UK
  • Redomiciliation
  • Formation of a new holding company
  • Consequences of outbound migration
  • Notification
  • More...

Outbound migration

Reasons for an outbound migration

Migration describes the situation when a company changes its tax residence. Some companies migrate from the UK overseas as a way of escaping UK taxation and taking advantage of lower tax rates that may be available in other jurisdictions.

Alternatively, commercial factors may make it preferable for a company to be incorporated in the UK (for example, because the process of incorporation is faster and simpler in the UK than in many other countries) but be tax resident in another country, eg all the directors may be resident in that country.

In either case, it is necessary to consider the tax position of the new company.

The Government is currently consulting on whether or not to introduce a corporate re-domiciliation regime. Such a regime may, or may not, include provision for outward re-domiciliation. The consultation closes on 7 January 2022.

See the Holding companies guidance note.

Methods of outbound migration

There are a number of ways in which a company can transfer its tax residence from the UK to another country.

Company incorporated in the UK with no double tax treaty in place between the UK and the other country

The company will remain resident in the UK because it is incorporated in the UK. If it becomes resident in the other country under the tax rules there, it will be treated as a dual resident company in the absence of a double tax treaty.

Company incorporated in the UK and double tax treaty is in place between the UK and the

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