Case law rule

Ceasing to be UK resident

Central management and control

Central management and control test

Cessation of business

Change of

Chargeable gains

Determination, rules for

Disposal of business

Disposal of shares as settlors of non-resident settlements

Domicile

Double taxation agreements

Generally

Non-resident under

Double taxation agreements, tie-breaker clause

Dual resident companies

European Company (SE) transfer of registered office to the UK

European Cooperative Society (SCE) transfer of registered office to the UK

Implications of UK residence

Incorporated in the UK

Incorporation rule

Migration of companies

Non-resident companies

Ordinary residence

Permanent establishment

Place of effective management company incorporated in the Netherlands

Rules for determining

Case law rule

Central management and control test

Change of residence

Companies treated as non-resident, tie-breaker rule

Domicile

Dual resident companies

Generally

Implications of residence

Incorporation rule

Ordinary residence

Transfer

Abroad, consent

Between member states

Reduction in capital tax

Unrealised capital gains, freedom of establishment

Transfer of assets abroad

Winding up