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Capital Gains Manual

CG42311 - Migration of companies: changing a company's residence: 15/3/88-29/11/93

Because of the incorporation rule, see CG42302, and the absence of any special rule for `treaty non-resident' companies, see CG42321, for the period from 15 March 1988 to 29 November 1993 it would be exceptional for a company incorporated in the UK to be able to migrate.

A company incorporated in a country outside the UK will only have been resident in the UK if the central management and control of the company has been exercised in the UK. In the period from 15 March 1988 to 29 November 1993 such a company can migrate by transferring its central management and control outside the UK.