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HMRC internal manual

Double Taxation Relief Manual

Grenada: Residence

A person 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). The benefits of the treaty will not be available for 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. Where a company which is incorporated in the United Kingdom, but managed and controlled in Grenada, claims to be a resident of Grenada, no claim should be admitted and the case should be referred to CT & VAT International CT.