Dominic Stuttaford and Ed Denny assess the impact of the Advocate General's Opinion in the case of National Grid Indus BV
For groups looking to restructure their operations by moving the residence of their subsidiaries exit taxes have long been much debated.
As far as the UK is concerned the tax residence would be moved by changing the location of the company’s central management and control to another jurisdiction.
A charge is imposed on what is in many cases a notional gain on the growth in value of a particular asset whether it...
