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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Greece: Residence

An individual who is resident in one country and is also resident in the other country (where the country is Greece, resident or domiciled in Greece) is not a resident of either country for the purposes of the agreement (INTM154020). The benefits of the agreement will not therefore be available to such dual residents.

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