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Corporate residence: who decides?

 
Sara Luder and Philip Higham of Slaughter and May consider corporate residence in the light of the recent First-tier Tribunal decision in Laerstate BV v HMRC
 
Corporate residence has been a hot topic in the last 18 months or so particularly in the context of recent corporate migrations or 'inversions'. Various UK listed companies have inserted non-UK-incorporated holding companies which are intended to be 'centrally managed and controlled' from outside the UK and so not resident in the UK for tax purposes. These transactions will undoubtedly be carefully scrutinised by HMRC. Its recent victory before the First-tier Tax Tribunal in Laerstate BV v HMRC

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