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Reasons for an inbound migration

Migration describes the situation when a company changes its tax residence. A company which is not incorporated in the UK may become resident for tax purposes in the UK if it becomes centrally managed and controlled in the UK.

The Government has consulted on whether or not to introduce a corporate re-domiciliation regime, with the summary of responses published on 12 April 2022. An independent expert panel on corporate re-domiciliation published its report on the proposal on 1 October 2024. The Government has stated that it intends to consult in due course on a proposed regime design.

See the How to establish if a company is UK resident guidance note.

In many cases, this may happen accidentally, but a well-advised company will avoid this by taking appropriate action to ensure that central management and control is kept outside the UK.

However, in some cases, there may be tax benefits of a company becoming resident in the UK, for example:

1. •

   to take advantage of a UK double tax treaty

2. •

   to avoid the application