Up to 29 November 1993, a UK resident company may, without
losing its UK resident status, become a resident of another country
for the purpose of the double taxation agreement between the UK and
that country. It might do this by moving its place of effective
management to the other country. This is known as a 'treaty
migration' and the company is then known as a treaty non- resident
company. Although the company remains UK resident under domestic
law we may have lost the right to tax some income and gains, as we
may in the case of a genuine migration. TCGA92/S186 provided for a
charge on certain unrealised chargeable gains or losses of such a
company (see CG42460 to CG42490).
From 30 November 1993, Section 186 is repealed because a
treaty migration becomes an actual migration and TCGA/S185 applies
instead.
