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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Migration of companies: changing a company's residence: from 30/11/93

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. However it may be dual resident and possibly treaty non-resident. From 30 November 1993 such a company will migrate if

  • it transfers its central management and control outside the UK


  • it is treaty non-resident on 30 November 1993 or it subsequently becomes treaty non-resident.