Speed Read: Multinational headquarters are becoming more mobile and the UK is being matched in non-tax attractions by many competitor countries, leaving taxation as a key differentiator. In this respect, the key element is the foreign holding company tax regime. In particular, the tax benefits derive from reorganising the group so that UK and foreign tax planning can be carried out without UK CFC implications. A detailed analysis of issues, costs and benefits is required and not only tax residence, transaction taxes and shareholder taxes, but legal and commercial aspects must be carefully managed.
