Families relocate corporate shells all the time; moving operating companies is harder. This guide covers tax frictions and cleaner migrations.
Know your start and end rules. Some countries allow statutory redomiciliation; others require liquidation/reincorporation. Tax may treat the move as a deemed disposal of assets—an “exit tax.” Map both sides.
Balance sheet triage. Identify assets that could crystalize gains: IP, goodwill, intercompany loans, inventory. Consider step-ups or valuations where recognized by the destination.
Creditors & contracts. Banking, leases, supplier terms, and covenants can block a paper move. Align legal, tax, and commercial changes.
People move with companies. If management stays behind, the new entity may fail substance tests. Budget for directors, office space, and payroll.
Sequencing. Stage pre-move cleanups (e.g., settle intercompany balances), re-paper critical contracts, change invoicing, and then file.
Case snapshot. A holding company migrates to a treaty hub that recognizes a fair-value step-up; the group books new tax bases and aligns directors and treasury there to satisfy residence and substance tests.
FAQ
- Can I redomicile mid-audit? Risky; resolve major disputes first.
- Will banks let me keep the same accounts? Often you’ll refresh KYC; plan for parallel runs.
Editor’s Note: Corporate migrations succeed when legal, tax, and banking move in the same week—not in three different quarters.
Tags: Redomiciliation, Exit Tax, Substance, Governance