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HMRC internal manual

Capital Gains Manual

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.