UK corporation tax is charged on companies (and certain other bodies) that are resident in the UK. A company is resident in the UK for the purposes of the Taxes Acts if it is incorporated in the UK (with certain exceptions) or if the central management and control of its business is in the UK. Wood v Holden, as recently applied in Development Securities, confirms that the meaning of central management and control is primarily a question of fact, i.e. where it is actually to be found, not the place where it ought to be exercised, and influence and wishes are not the same as management and control.
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UK corporation tax is charged on companies (and certain other bodies) that are resident in the UK. A company is resident in the UK for the purposes of the Taxes Acts if it is incorporated in the UK (with certain exceptions) or if the central management and control of its business is in the UK. Wood v Holden, as recently applied in Development Securities, confirms that the meaning of central management and control is primarily a question of fact, i.e. where it is actually to be found, not the place where it ought to be exercised, and influence and wishes are not the same as management and control.
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