Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
, see all updates

Solomon Islands: 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 be unable to obtain any benefits of 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 the Solomon Islands, claims to be a resident of the Solomon Islands, the case should be referred to Business International before enquiries are raised on the issue.