Client Alert

| January 20, 2010

UK Redomiciliations – What is the Risk of a Successful HMRC Residence Challenge?

After a run of corporation tax residence cases in which the UK tax authorities have lost, the First-Tier Tax Tribunal decided last August that a Dutch-incorporated company was, in fact, UK tax resident on the “central management and control test” (Laerstate BV v. HMRC).

For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:

Judith Harger

+44 20 7459 5185

Graham Brough

+44 20 7459 5230

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383