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HMRC internal manual

Double Taxation Relief Manual

Gambia: Residence

The agreement provides that a person is a resident of one country if he is liable to taxation in that country by reason of his domicile, residence, place of management or any other criterion of a similar nature. The agreement does not have the normal special rules for determining of which country a person is a resident for treaty purposes where he is resident in each country under each country’s own domestic law.

For the purposes of the agreement where, under domestic law, a company is a resident of both countries, it will be treated as a resident of the country in which its business is managed and controlled.