CG42313 | Migration of companies: changing a company's residence: from 30/11/93

The combined effect of the incorporation rule, see CG42302, and the treaty non-resident rule, see CG42303, is that from 30 November 1993 a UK incorporated company

• will migrate if it is treaty non-resident on 30 November 1993 or it subsequently becomes treaty non-resident

but

• it would be exceptional for such a company to migrate in any other circumstances.

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. However it may be dual resident and possibly treaty non-resident. From 30 November 1993 such a company will migrate if

• it transfers its central management and control outside the UK

or

• it is treaty non-resident on 30 November 1993 or it subsequently becomes treaty non-resident.