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HMRC internal manual

Capital Gains Manual

Migration of companies: changing a company's residence: from 30/11/93

The combined effect of the incorporation rule, see CG42302, and the treaty non-resident rule, see CG42303, is that from 30 November 1993 a UK incorporated company

  • will migrate if it is treaty non-resident on 30 November 1993 or it subsequently becomes treaty non-resident


  • it would be exceptional for such a company to migrate in any other circumstances.