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HMRC internal manual

Double Taxation Relief Manual

Malawi: Resident

An individual who is a resident of one country and also resident in the other country is not a resident of either country for the purposes of the agreement (see INTM154020). Such a dual resident individual will not be entitled to any of the benefits provided by the agreement.

A company is a resident of the country in which it is taxed as a resident either because it is managed and controlled in that country or because it is incorporated there. Where a company which is incorporated in the United Kingdom, but managed and controlled in Malawi, claims to be a resident of Malawi, no claim should be admitted and the case should be referred to Business International.