Outbound migration

Produced by

Corporation Tax

Guidance

Reasons for an outbound migration

Migration describes the situation when a company changes its tax residence. Some companies migrate from the UK overseas as a way of escaping UK taxation and taking advantage of lower tax rates that may be available in other jurisdictions.

Alternatively, commercial factors may make it preferable for a company to be incorporated in the UK (for example, because the process of incorporation is faster and simpler in the UK than in many other countries) but be tax resident in another country, eg all the directors may be resident in that country.

In either case, it is necessary to consider the tax position of the new company.

The Government is currently consulting on whether or not to introduce a corporate re-domiciliation regime. Such a regime may, or may not, include provision for outward re-domiciliation. The consultation closed on 7 January 2022 and the response is expected to be published by HMRC in due course.

See the Holding companies guidance note.

Methods of outbound migration

There are a number of ways in which

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Anne Fairpo

Barrister

With effect from 1 June 2021, Anne Fairpo is a judge of the First-tier Tribunal sitting in the Tax Chamber. She was previously a fee-paid judge in the same Chamber. Her contributions to LexisPSL Tax and TolleyGuidance were written before her full-time appointment and are her personal view as she is not authorised to write on behalf of the Tribunals Service or the judiciary. Until April 2021, Anne was a tenant at Temple Tax Chambers. She was called to the bar in 2009 after 15 years as a solicitor. Anne’s experience and expertise covers UK and international corporate tax planning and disputes, having acted for a range of clients from small owner-managed businesses to listed multinationals, as well as having advised on intellectual property taxation and UK-US cross-border tax planning, with regard to both direct and indirect tax matters

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