Overview

Corporate Residence is about the UK’s approach to determining the residence status of corporations and thus their exposure to UK tax. If companies are not managed and controlled in the correct way they could unintentionally become UK resident and so be rendered subject to UK taxes. The question of where a company is actually resident has become increasingly significant, with the international nature of so many business transactions today, including e-commerce transactions. Contents: 1. Corporate Residence; 2. The Importance of UK Residence Status; 3. The Statutory Rules; 4. Central Management and Control – the case law test; 5. Recent Case law: Wood v Holden, Datacom and Laerstate; 6. Corporate residence and tax treaties; 7. Treaty tiebreaker provisions; 8. Directors’ meetings; 9. Communication between the UK and overseas; 10. The application of the case law test to subsidiaries; 11. The Memorandum and Articles of Association; 12. HMRC practice; 13. Avoiding a Residence Enquiry; 14. HMRC’s Enquiry into Residence – Practical Case Studies.

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9781847663696

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David Hughes BBS MA (TCD) ACA CTA (Fellow) AITI ADIT TEP specialises in international private client taxation. He has written many articles on UK and international taxation issues for leading UK and foreign journals.

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