Tax

The Government’s proposed UK corporate re-domiciliation regime would allow foreign companies to move their place of incorporation to the UK while preserving legal identity, but only on an inward basis, leaving no route for UK companies to re-domicile overseas. Tax policy remains largely undeveloped, with the consultation focusing on issues including market value rebasing, loss treatment, corporate residence, treaty access and stamp taxes. Re-domiciliation itself should not trigger stamp duty or SDRT, although practical concerns remain for certain listed companies. Proposed market value rebasing and restrictions on surrendering post-re-domiciliation losses aim to balance competitiveness with avoidance risks, while many anticipated tax advantages, including treaty access and QAHC eligibility, may already be available through UK tax residence alone.

*This article first appeared in the 17 July 2026 issue of Tax Journal.