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HMRC internal manual

Company Taxation Manual

Residence: outward company migration: from 15 March 1988

A company incorporated in the UK which is resident here under the incorporation rule of CTA09/S14 (introduced as FA88/S66) does not cease to be resident if it transfers its central management and control out of the UK, except where CTA09/S18 (formerly FA94/S249) applies. A company incorporated outside the UK can cease to be resident by transferring its central management and control outside the UK. Companies which intend to migrate must comply with rules introduced by FA88/S130 to S132, outlined at CTM34160 onwards. Under Tax Law Rewrite, the rules were relocated by TIOPA10/SCH7/PART10 to TMA70/S109B to 109F.

The Treasury consent rules (see CTM34110), which had remained in place in restricted form as an anti-avoidance measure, were repealed entirely by FA09/SCH17 and replaced with a reporting requirement under the heading ‘international movement of capital’ - see INTM700000 onwards, and in particular INTM700110. The rules aimed at collecting the outstanding tax liabilities left behind by migrating companies are now at TMA70/S109B to S109F.