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 arrangement (see DT3526). No benefits of the arrangement will be available to such a dual 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. If a company which is incorporated in the United Kingdom, but managed and controlled in Belize, claims to be a resident of Belize, no claim should be admitted and the case should be referred to Business International.
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