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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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St Christopher (St Kitts) and Nevis: 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. Such a dual resident will not be able to obtain any benefits available under 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 St.Kitts and Nevis, claims to be a resident of St.Kitts and Nevis, the case should be referred to Business International before enquires are raised on the issue.