Relocation, relocation, relocation

There are many commercial reasons why a company or group may want to relocate its operations or management functions. A company may move its assets or functions out of the UK whether by a change of residence of a UK company; the insertion of a new non-UK holding company; or the relocation of specific assets and functions. Each of these options will have its own UK tax implications. These options have been affected by developments in international tax law in recent years including: changes to corporate residence tests as a result of ratification by relevant countries of the multi-lateral instrument changes to UK exit charges arising when a company moves its residence outside of the UK required following the introduction of the EU anti-tax avoidance directive (ATAD) CJEU case law affecting the substance requirements that a company may be required to meet if it is to...