This overview summarises the tax issues for a UK-based multinational wishing to move its tax residence from the UK, and explains how this can be achieved in practice. It covers reasons for corporate emigration, migrating an existing company, introducing a new holding company, post-implementation reorganisations and dividend access arrangements.
This article is part of the PLC multi-jurisdictional guide to Tax on Transactions. For a full list of contents visit www.practicallaw.com/taxontransactionshandbook. Dividend tax is frequently referred to the ECJ and various EU member states have had aspects of their domestic legislation struck down. The European Commission has taken legal action against a number of member states whose dividend rules do not comply with the EC Treaty (TFEU). This article examines the legal framework, inbound dividends, outbound dividends, whether double-tax treaties can cure discrimination, and EEA and third countries.