Company Migration
Company migration involves changing the jurisdiction of tax residence or incorporation of a company, either into or out of the UK. Whether you are expanding internationally or relocating your central management overseas, we ensure the migration is structured in a commercially appropriate and tax-efficient manner, with the necessary HMRC notifications and clearances obtained.
What are the benefits?
Exit Tax Planning
A company ceasing UK tax residence is treated as disposing of all its assets at market value on the date of migration, potentially triggering a UK Corporation Tax charge. We assess the exit tax exposure and identify any available reliefs or deferral mechanisms.
HMRC Clearance
HMRC must be notified of a company's intention to migrate, and in many cases an application for a formal clearance or agreement on the exit tax position is advisable. We manage this process to provide certainty before migration.
Post-Migration Tax Position
We advise on the tax position in the destination jurisdiction, ensuring the migration achieves the intended commercial and tax objectives. We work with local advisers in the destination jurisdiction where needed.
Transfer Pricing Implications
Following migration, transactions between a UK entity and the migrated company will likely be subject to UK transfer pricing rules. We advise on the appropriate pricing policies and documentation requirements.
How can Zenus Tax help?
We assess the exit tax exposure and advise on mitigation strategies
We manage the HMRC notification and clearance process
We coordinate with legal advisers and overseas tax advisers
We advise on post-migration compliance obligations in both jurisdictions
Frequently Asked Questions
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