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HMRC internal manual

Capital Gains Manual

Migration of companies: company residence

The rules determining where a company is resident for taxation purposes depend on theperiod under consideration. Depending on what period you are dealing with you will need toconsider one or more of the following.

  • Where the central management and control of the company is exercised.
  • Where the company is incorporated.
  • Whether the company is `treaty non-resident’, see CG42321.