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.

Jill Gatehouse, Josh Critchlow and Alison Dickie from our London tax team consider some of the questions in the consultation about the UK tax consequences of the proposals in the briefing at the link below. Areas for consideration include the relationship between domicile and residence, impact on realised losses, latent losses and latent gains, amortisation, SDRT and source.

This briefing was originally published in Tax Journal on 3 December 2021.