UK companies seeking to minimise tax bills by locating abroad would face years of scrutiny to ensure senior management decisions have genuinely relocated, a senior official at HM Revenue & Customs has said.

Firing a warning shot across the bows of companies thinking of emigrating, Dave Hartnett, permanent secretary for tax at HMRC, told the Financial Times he was not convinced that relocations could be done in a “clean way” and warned that a challenge could come years after the move.