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HMRC internal manual

Company Taxation Manual

Residence: dual resident companies: advice from Head Office

In any case of doubt as to whether a company is a dual resident investing company or not and in particular any case where any of the activities is an issue, officers may seek advice from CTIS (Business International). There is no provision for statutory ‘clearances’ in this connection but any requests for ‘clearance’ should be forwarded to CTIS, with the file and a copy of the latest accounts for the dual resident company that can be provided by the group or their agents.