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Liabilities that might arise on a corporate change of residence
We act on behalf of a UK-resident company. The sole shareholder is a Uruguayan national who is not resident in the UK. The company’s only asset is a property on Sardinia which has been let in recent years with expenditure exceeding income.
The accounting records are maintained by lawyers in Liechtenstein two of whom are directors of the company along with the writer of this query. The shareholder wishes to transfer what he calls the “legal seat” of the company to Liechtenstein.
It is our view that the move to Liechtenstein would result in a substantial corporation tax liability on the huge increase in the value of the Sardinian property since it was acquired many years ago.
Is this the case and there are other possible pitfalls and liabilities?
Query 18 572 – Hansel
Reply from Andrew Murray Milestone Tax
The simple answer is...
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