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Reasons for an outbound migration

Migration describes the situation when a company changes its tax residence. Some companies migrate from the UK overseas as a way of escaping UK taxation and taking advantage of lower tax rates that may be available in other jurisdictions.

Alternatively, commercial factors may make it preferable for a company to be incorporated in the UK (for example, because the process of incorporation is faster and simpler in the UK than in many other countries) but be tax resident in another country, eg all the directors may be resident in that country.

In either case, it is necessary to consider the tax position of the new company.

See also the Holding companies guidance note.

Methods of outbound migration

There are a number of ways in which a company can transfer its tax residence from the UK to another country.