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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Netherlands: Company residence

Under Article 4(4), the competent authorities shall determine the residence under the treaty of those companies that are dually resident in the Netherlands and the United Kingdom under their respective domestic laws.

Article 4(3) of the previous agreement provided a dual resident company was deemed to be a resident of the country in which its place of effective management was situated.