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Official guidance
Capital Gains Manual

CG42300P · Capital Gains Manual: Companies and Groups of Companies: Effects of residence and migration on companies: Migration of companies

  • CG42300 · Migration of companies: company residence
  • CG42301 · Migration of companies: company residence: pre- 15/3/88
  • CG42302 · Migration of companies: company residence: 15/3/88-29/11/93
  • CG42303 · Migration of companies: company residence: from 30/11/93
  • CG42310 · Migration of companies: changing a company's residence: pre-15/3/88
  • CG42311 · Migration of companies: changing a company's residence: 15/3/88-29/11/93
  • CG42313 · Migration of companies: changing a company's residence: from 30/11/93
  • CG42315 · Migration of companies: residence: settlement of liabilities
  • CG42320 · Migration of companies: residence: company becoming dual resident
  • CG42321 · Migration of companies: residence: company becoming treaty non-resident
  • CG42350 · Migration of companies: arrivals in UK: becoming resident in UK
  • CG42360 · Migration of companies: departures from UK: ceasing to be resident in UK
  • CG42370 · Migration of companies: exit charges
  • CG42380 · Migration of companies: restriction of roll-over relief on ceasing UK residence
  • CG42390 · Migration of companies before January 2020: postponement of exit charges
  • CG42400 · Migration of companies before January 2020: recovery of charges postponed under TCGA92/S187
  • CG42410 · Migration of companies before 1 January 2020: postponed charges: example
  • CG42420 · Migration of companies before 1 January 2020: recovery of postponed charges: example
  • CG42430 · Migration of companies before January 2020: reduction of recovery charge for unused losses
  • CG42312 · Migration of companies: changing a company's residence: 15/3/88-29/11/93
  • CG42314 · Migration of companies: changing a company's residence: from 30/11/93
  1. Capital Gains Manual: Companies and Groups of Companies: Effects of residence and migration on companies: Migration of companies: Contents
  2. Migration of companies: company residence: from 30/11/93

CG42303 | Migration of companies: company residence: from 30/11/93

From HM Revenue & Customs · Capital Gains Manual

FA94/S249

From 30 November 1993 onwards FA94/S249 introduced a rule that all `treaty non-resident’ companies, see CG42321, are not resident for all taxation purposes. The incorporation rule still applies. As a result

  • all companies incorporated in the UK are resident here except-

  • those exempted from the incorporation rule by FA88/SCH7

and

  • `treaty non-resident’ companies.

  • all companies incorporated outside the UK whose central management and control is exercised in the UK are resident here except those which are `treaty non-resident’.

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