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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Migration of companies: residence: company becoming dual resident

A company incorporated in the UK which transfers its central management and control outside the UK may become a resident of another country under the tax laws of that country. From 15 March 1988 such a company would be resident in both the UK (incorporation rule) and the other country. Such a company is described as dual resident.

Similarly a company incorporated outside the UK that exercises its central management and control in the UK will be resident in the UK on that test but may also be resident in another country under the domestic laws of that country. Again, such a company is described as dual resident.