HMRC is currently active in challenging corporate residence, often deploying arguments which seek to move the debate beyond the terms set by Wood v Holden. Despite a recent HMRC victory in Development Securities, the law in this area has not fundamentally changed (or at least not yet). Given the current focus on offshore matters, however, overseas companies may find they need to improve their governance processes if they are going to preserve their residence outside the UK.
d914bf2e-d173-4943-bcb6-614ae89aac7d.jpg?sfvrsn=69df3123_1)
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
