I have a feeling that they don\’t:
If companies are found not to have moved high-level staff in appropriate numbers, firms may be levied fines and forced to pay back tens of millions of pounds in tax.
A senior HMRC source said: \”We will be looking for substantial evidence that a move has taken place and is genuine. We will want to see emails to establish there has been a physical relocation and that the brains of the company has moved.\”
For where (within EFTA) a company is tax resident is not a matter of British law any more. It\’s a matter of EU law. And that EU law says that it\’s where the brass plate is.
That\’s pretty much it: EU law is superiror (not in the sense of being better of course, solely in the sense of superseding) UK law and there\’s an end to it.
Try looking up the \”Bolkestein Directive\”.
Update. As usual, Ritchie doesn\’t get it.