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HMRC internal manual

Capital Gains Manual

Migration of companies: company residence: from 30/11/93

FA94/S249From 30 November 1993 onwards FA94/S249 introduced a rule that all `treaty non-resident’ companies, see CG42321, are not resident for all taxation purposes. The incorporation rule still applies. As a result

  • all companies incorporated in the UK are resident here except-

    • those exempted from the incorporation rule by FA88/SCH7


    • `treaty non-resident’ companies.
  • all companies incorporated outside the UK whose central management and control is exercised in the UK are resident here except those which are `treaty non-resident’.