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Relocation, relocation, relocation

Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving 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

There are many reasons why a corporate group may decide to relocate assets or functions. These may include a desire to align the company or group structure with developing markets or as a result of actual or anticipated changes in the political tax or regulatory environment.

This article reviews some of the different mechanisms a group may consider when looking at relocating activities and functions from the UK. It is not comprehensive but we have focused on some of the key structural issues and recent developments.

Corporate migration

One means of changing the international footprint of a company or group...

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