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UK corporate re-domiciliation: time to make a move?

Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.

As part of the Autumn Budget the UK government published a consultation seeking views on the introduction of a new UK corporate re-domiciliation regime. The domicile of a company is typically the jurisdiction under whose laws that company is incorporated or registered. Corporate re-domiciliation is the process whereby a company transfers its domicile from one jurisdiction to another whilst maintaining or continuing its legal identity as a corporate body (hence this process is also referred to as a ‘continuation’ in some jurisdictions). While the proposals primarily require changes to the UK corporate law regime it raises interesting questions about the tax consequences of this proposed regime and we explore a number of these below.

A company incorporated in the UK cannot currently re-domicile...

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