CTM34120 | Residence: outward company migration: from 15 March 1988
From HM Revenue & Customs · Company Taxation Manual
A company incorporated in the UK which is resident here under the incorporation rule of (introduced as ) does not cease to be resident if it transfers its central management and control out of the UK, except where (formerly ) applies. A company incorporated outside the UK can cease to be resident by transferring its central management and control outside the UK. Comp anies which intend to migrate must comply with rules introduced by to S132, outlined at onwards. Under Tax Law Rewrite, the rules were relocated by to to S109F.
The Treasury consent rules, see , which had remained in place in restricted form as an anti-avoidance measure, were repealed entirely by and replaced with a reporting requirement under the heading ‘international movement of capital’ - see onwards, and in particular . The rules aimed at collecting the outstanding tax liabilities left behind by migrating companies are now at to S109F.