Transfer of Registered Office

If emigration taxes imposed by a country have as only purpose to compensate for the awarded benefit, there is in principle little that can be done against this. This is certainly justified. But, in practice, we will often notice that emigration taxes go one or two steps further than this and in such event a discussion on their validity may arise.

Obviously, even the smallest emigration tax will have a dissuasive effect on the company that is subject to the tax. Even if a compensation is charged for the benefits awarded in the past to these companies, we will see that this puts a brake on international transfers of registered offices.

It is a very thin line between what in case law and literature is considered as a correct or excessive compensation.

Link: Fiscal consequences of transfer of registered office to another country