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HMRC internal manual

International Manual

Company residence: when HMRC will not usually review residence: individual directors

Location of individual directors

The relevance of individual directors’ tax residence to the place of central management and control of the companies that they serve is sometimes raised as an issue. In principle it is the place from which an individual exercises central management and control that is the relevant factor for locating the residence of a company rather than the territory in which their personal tax liabilities arise.