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HMRC internal manual

Double Taxation Relief Manual

Montserrat: Resident

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 Montserrat, claims to be a resident of Montserrat, the case should be referred to Business International before the claim is admitted.