Back to basics: Corporate tax residence

UK resident companies are subject to tax on their worldwide profits. A company will be resident in the UK if it is incorporated in the UK, or centrally managed and controlled in the UK. Case law has established the definition of central management and control and there are a number of practical steps which can be followed to ensure that management and control is outside the UK. Dual residence may be dealt with under UK legislation or double tax treaties, but special rules apply to dual resident investing companies.