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The government is seeking views on proposals to introduce of a UK re-domiciliation regime, including:
The proposals would make it possible for companies to re-domicile, making it easier for them to relocate to the UK.
The consultation was issued by:
We support the introduction of a UK corporate re-domiciliation regime that permits inward and outward re-domiciliation.
In our responses, we comment in detail on:
The conditions must be objective, and businesses must be able to predict outcomes with a high degree of certainty.
The re-domiciliation process should be clear and simple, and the requirements for inward re-domiciliation should be as similar as possible to those required for a new incorporation of a body corporate in the UK.
From a practical perspective, a well-resourced team at Companies House, familiar with the re-domiciliation process, will be critical to the success and smooth operation of the new regime.
In response to the technical chapter on tax issues, we comment on:
We would welcome clarity on how inward and outward re-domiciliation will impact a company’s UK corporate tax residence.
A UK inward and outward re-domiciliation regime would increase the attractiveness of the UK as a jurisdiction in which to:
We see this as part of an overall package that aims to make the UK a more attractive place to do business.
The consultation closed on 7 January 2022.
The government will first analyse the feedback from the consultation.
If a UK re-domiciliation regime is introduced, it would need to be enacted by primary legislation.