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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Antigua and Barbuda: 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).

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 Antigua and Barbuda, claims to be a resident of Antigua and Barbuda, no claim should be admitted and the case should be referred to Business International.