Analysis — Inward Migration

Speed Read: Recent economic conditions have led to a decline in the value of group-held assets together with the dreaded anticipation of substantial losses on disposal of such assets. Typical assets currently standing at a loss in many groups include foreign property investments or trades. These investments held may have been structured to provide for maximum tax efficiencies on sale with the inherent assumption that the relevant asset would be sold on at a profit. Unfortunately not enough thought may have been given by some groups to the reality that such investments might prove loss-making (at least in the short or medium term) or that any anticipated tax benefits could be outweighed by high compliance costs in maintaining an offshore structure. Groups with significant UK operations may now find that their foreign subsidiaries holding such loss-making foreign investments are unable to fully benefit from losses in these foreign...