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HMRC internal manual

Capital Gains Manual

Residence and migration: companies: meaning of terms

Guidance on the meaning of the term residence can be found at CG42300+.

The concept of domicile does not need to be considered for companies and the decision on the residence status of a company governs the whole of its treatment in this area. This is a decision to be made by Inspectors. They should use the guidance in INTM120000 onwards in making the decision.

The United Kingdom does not include the Isle of Man or the Channel Islands.