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HMRC internal manual

Company Taxation Manual

Residence: inward company migration: establishing residence

A company which is resident outside the UK may move its place of central management and control to the UK and so become resident in the UK. It is quite likely to retain its residence abroad, typically through being incorporated in a country that uses incorporation as a test of residence. In such a case it will become a dual resident company. In that event it will usually be necessary to examine the terms of the Double Taxation Agreement, if any, between the UK and the other country in order to determine residence under that agreement. From 30 November 1993 if residence is awarded solely to the other country, the company does not become UK resident.

An officer who becomes aware that a company has become resident in the UK under our domestic case law rule should set up the case in the normal way - see COM40072. The claim to have transferred central management and control to the UK may well need investigation - see INTM120000 onwards.