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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Residence: dual resident companies: reports to Business International

Report to CTIS (Business International) any case where it appears that attempts are being made to retain advantages to the group in the UK and overseas similar to those previously provided by dual resident investing companies. For example, groups may arrange their affairs so that substantial interest payments are made either in the UK or overseas which are balanced by income arising in low tax jurisdictions.