CTM34530 - Residence: dual resident companies: definition
A company is a dual resident company in any accounting period in which it is resident in the UK, under the UK바카라 사이트™s central management and control test, if it is also within the charge to tax under the laws of a territory outside the UK by reason of certain conditions. It should be noted that 바카라 사이트˜territory바카라 사이트™ is a wider term than 바카라 사이트˜country바카라 사이트™ and encompasses a State or other political sub-division.
To be a dual resident company a company must be within the charge to tax in a territory because one of the following applies.
- It derives its status as a company under the general body of law in that territory. This covers countries that tax by reference to the place of incorporation, such as the United States and Australia.
- Its place of management is in that territory. This covers countries that regard a company as resident in a territory because of the location of the management or seat of business, such as Germany.
- It is for some other reason treated as resident for the purposes of the charge under the overseas law relating to taxation. This covers countries that tax on a basis similar to the UK test of central management and control, such as the Republic of Ireland.