---
title: "Moving a company’s tax residence"
url: https://www.boruconsulting.com/glossary/situations/moving-company-residence
type: ItemList
reviewed: 2026-11-10
---

# Moving a company’s tax residence

> Re-registering a company in the UAE is the easy part: its tax residence moves only if genuine control moves with it, and leaving the old country’s tax net can trigger a charge on the way out.

## The concepts this turns on

1. [Redomiciliation](https://www.boruconsulting.com/glossary/redomiciliation) — Mechanism | UAE
   The transfer of a company’s registration from one jurisdiction to another without winding it up and forming a new entity, so the same legal person continues with its contracts and history intact. UAE common-law free zones such as the ADGM and DIFC allow companies to redomicile in.
2. [Share-for-Share Exchange](https://www.boruconsulting.com/glossary/share-for-share-exchange) — Mechanism | UK · IE · UAE · AU
   A transaction in which shareholders transfer their shares in a company to a new company in return for shares in it, so the new company becomes the parent and the group is re-headed without selling the business. It is a disposal in principle, but many tax systems roll the gain into the new shares instead of charging it at the time.
3. [Central Management and Control (CMC)](https://www.boruconsulting.com/glossary/central-management-and-control) — Legal test | UK · IE · UAE
   The long-standing test that treats a company as tax resident where its real top-level decisions are actually made, rather than where it is registered. A founder who relocates but keeps controlling the company from the old country may not have moved its residence at all.
4. [Corporate Tax Residence](https://www.boruconsulting.com/glossary/corporate-tax-residence) — Status | UK · IE · UAE
   The test that decides which country has primary taxing rights over a company, usually based on where it is incorporated or where its central management and control sits. A company can be resident in more than one country, which double taxation agreements then resolve.
5. [Exit Tax](https://www.boruconsulting.com/glossary/exit-tax) — Tax charge | UK · IE
   A charge on unrealised gains that arises when a company or individual ceases to be tax resident in a country, treating the assets as sold at market value on departure. It stops accrued gains leaving the tax net simply because the taxpayer moves.

Related: [Moving a company to another country](https://www.boruconsulting.com/blog/move-company-to-another-country)

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Source: https://www.boruconsulting.com/glossary/situations/moving-company-residence