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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: changing a company's residence: 15/3/88-29/11/93

CG42311 | Migration of companies: changing a company's residence: 15/3/88-29/11/93

From HM Revenue & Customs · Capital Gains Manual

Because of the incorporation rule, see CG42302, and the absence of any special rule for `treaty non-resident' companies, see CG42321, for the period from 15 March 1988 to 29 November 1993 it would be exceptional for a company incorporated in the UK to be able to migrate.

A company incorporated in a country outside the UK will only have been resident in the UK if the central management and control of the company has been exercised in the UK. In the period from 15 March 1988 to 29 November 1993 such a company can migrate by transferring its central management and control outside the UK.

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