Publications · Residency · July 2026

Moving a principal without moving the structure.

A change of residence does not relocate the companies, the accounts or the assets, and the interval in which the two are misaligned is where most of the cost arises. The sequence in which the steps are taken determines how long that interval lasts.

A principal moves. The companies do not. The accounts do not. The property, the portfolio and the shareholdings stay exactly where they were, held by entities formed for a set of circumstances that has now changed. Nothing has broken, and for a period nothing appears to be wrong, which is precisely what makes the position difficult to address at the moment it can still be addressed cheaply.

The misalignment is temporary in principle and often permanent in practice, because the point at which it becomes visible is usually a bank review, a filing deadline or a request from a new authority, and by then several of the useful options have closed. The work of a relocation is therefore less about the move itself than about the order in which the surrounding arrangements are put back into correspondence with it.

What moves and what does not

Personal residence moves with the principal, subject to the tests the departure jurisdiction and the arrival jurisdiction each apply, which are not the same tests and do not always produce the same answer at the same moment. Corporate residence does not move with the principal automatically, but it may move without anyone intending it to, because a company directed by a person who now sits somewhere else may acquire management and control in the new location while retaining its registration in the old one.

Banking relationships move least readily of all. An account opened on the basis of a resident principal, a local address and a stated pattern of activity is reviewed against that basis, and a change to any of the three is a change the institution is entitled to consider afresh. Assets move only if they are moved, and each class carries its own consequences on transfer, which is why the sequencing question is rarely answered the same way twice.

The cost of a relocation is determined almost entirely by the length of the interval in which the personal position and the corporate position describe two different people.

The order in which steps are taken

The first task is to establish, in writing, the position on the day before departure: where each entity is registered, where it is managed, who holds the accounts, what has been declared and to whom. This is unglamorous and frequently skipped, and it is the document every subsequent conversation refers back to. Without it, the group is reconstructing its own history from correspondence at the point when it is least convenient to do so.

Decisions that must be taken before departure are then separated from those that must wait until after arrival, and the two lists are not interchangeable. Matters that depend on the principal still being resident in the departure jurisdiction — certain reorganisations, certain distributions, certain filings — cannot be deferred. Matters that depend on establishing a position in the arrival jurisdiction cannot be brought forward. Between them sits a set of arrangements, particularly around board composition and where meetings are held, that determines whether corporate residence follows the principal by accident.

Telling the institutions before they ask

Banks, registrars and authorities will discover the move. The question is whether they discover it from the client or from a mismatch in their own records, and the difference in outcome between the two is considerable. A notification that arrives with an explanation, updated documentation and a coherent account of the structure is an administrative event. The same change surfacing during a periodic review, unexplained, is treated as an inconsistency and reviewed accordingly.

The same applies to advisers in both jurisdictions. Counsel and tax advisers who learn of the relocation after it has occurred are asked to remedy a position rather than to plan one, and their scope for doing so is narrower and more expensive. Where the move is coordinated across both jurisdictions from the outset, the arrangements on each side are at least built against the same set of facts, which is the minimum condition for the structure and the principal to describe the same person again.

This note is general in application and does not constitute legal, tax or regulatory advice. It describes practice observed across institutions and should not be relied upon in relation to any particular relocation.

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PublicationsTwenty-eight notes on structuring, banking, residency, tax and succession, written for principals and their advisers.Read the notes