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UK corporate re-domiciliation: time to make a move?

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The UK government recently published a consultation seeking views on the introduction of a new UK corporate re-domiciliation regime. While the proposals primarily require changes to the UK corporate law regime, one of the drivers for the proposals is to assist groups wanting to come to the UK by helping to avoid the need to undertake transactions which might have adverse tax implications. The consultation also asks questions about the UK tax consequences of the proposals. Areas for consideration include the relationship between domicile and residence, impact on realised losses, latent losses and latent gains, amortisation, SDRT and source.

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