Earlier today the government published its summary of responses to that consultation. This includes a firm statement that the government intends to introduce inward re-domiciliation, and leaves open the possibility that it may go further and allow UK companies to re-domicile overseas. There isn’t any detail of when the necessary legislation will be introduced, although the document hints that it may undertake further public consultation on the detailed design of the new rules first.

This is a relatively swift response to a consultation that closed in early January, and the continued impetus behind these proposals is to be welcomed. We consider that a UK re-domiciliation regime is an overdue reform that will make it much more straightforward for companies established in some civil law jurisdictions, such as Luxembourg, to migrate their tax residence to the UK. Those companies might include investment vehicles that may wish to take advantage of the new UK Qualifying Asset Holding Company rules.