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HMRC internal manual

Double Taxation Relief Manual

Luxembourg: Company residence

Under Luxembourg’s domestic law a company is regarded as resident in Luxembourg if it is incorporated in Luxembourg, founded under Luxembourg law or if its principal place of management is located in Luxembourg.

The place of the central management and control of a company’s business for the purposes of determining its residence under United Kingdom domestic law is not necessarily the same as the location of its `place of effective management’ for the purposes of the double taxation agreement. For a discussion of the distinction between these two terms see ITH348.