Corporate Tax Residence - Redomicile By UK Groups Using A Jersey Holdco

INTRODUCTION

Although HM Treasury recently withdrew its controversial proposals for the taxation of foreign profits of UK companies, there are continuing concerns that revised proposals will be introduced which may have the effect of damaging the competitiveness of UK multinationals.

Recent decisions by Shire Pharmaceuticals Group plc ("Shire") and United Business Media plc ("UBM") to migrate their tax domicile from the UK to the Republic of Ireland are indicative of such a perception. In the case of UBM, the reasons it gave for its decision to relocate its holding company were the significant compliance costs in managing the interaction between the UK tax system and the tax systems of the countries in which it operates.