When making the decision to migrate, it is important not just to consider the tax issues but also the more practical issues. The principal tax considerations are the tax rates in the new jurisdiction, the tax policy, CFC rules, transfer pricing and withholding issues. Practical considerations range from the macro issues (of whether the jurisdiction is the right jurisdiction for the particular business) to micro issues (including the appointment of directors; the infrastructure; communication system; legal system; political stability; and the availability of employees).
