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HMRC internal manual

International Manual

Company residence: what this guidance replaces

This guidance replaces the paragraphs on company residence which were previously found in the Company Tax Manual from CT3365 onwards. There are a small number of changes to the ordering of the material and a number of minor amendments and additions.

We have also re-published in its original form the material on company residence which was previously found in the International Tax Handbook (‘ITH’) from ITH300 onwards. This can now be found at INTM120210. Although the ITH has been withdrawn and replaced by the INTM, this material remains factually relevant for considering the central management and control test.

For ease of reference, the text of Statement of Practice 1/90 ‘Company Residence’ may be found at INTM120200.