Company residence: HMRC’s new guidance

SPEED READ HMRC has recently issued new guidance regarding company residence, including examples of circumstances in which it will not normally seek to enquire into the UK residence of an overseas company. Whilst this guidance is likely to be helpful in concluding a number of cases without the need for prolonged and costly investigations, caution should be applied in relying on the guidance which is heavily reliant on conditions and caveats. Best practice in this area therefore remains largely unchanged, although there is a hint that the focus of future HMRC activity in this area may be shifting.