HMRC has revised its interpretation of the residence articles in 16 double taxation agreements taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously HMRC regarded dual-resident companies as outside the scope of the treaties. See www.bit.ly/1NHeXTk.
HMRC has revised its interpretation of the residence articles in 16 double taxation agreements taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously HMRC regarded dual-resident companies as outside the scope of the treaties. See www.bit.ly/1NHeXTk.