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Vol 23 No 5 May/June 2018

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Cover of Drafting Commercial Agreements

Drafting Commercial Agreements

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Corporate Residence

ISBN13: 9781847663696
Previous Edition ISBN: 1847663516
Published: October 2013
Publisher: Bloomsbury Professional
Country of Publication: UK
Format: Paperback
Price: £140.00

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Corporate Residence is about the UK’s approach to determining the residence status of corporations and thus their exposure to UK tax. If companies are not managed and controlled in the correct way they could unintentionally become UK resident and so be rendered subject to UK taxes.

The question of where a company is actually resident has become increasingly significant, with the international nature of so many business transactions today, including e-commerce transactions.

Announced as Taxation and Corporate Residency

Company Law, Taxation
1. Introduction
2. The Importance of UK Residence Status
3. The Incorporation Rule
4. Central Management and Control (The Case Law Test)
5. FA 1994 S249 and the Impact of Tax Treaties on the Determination of Residence
6. Place of Effective Management
7. HMRC Practice
8. The Application of the Case Law Test to Subsidiaries
9. Peripatetic Boards
10. UK Coordination Centres
11. The Implications of Modern Forms of Communication
12. Directors Located in the UK and Overseas
13. Outside Interference: Shadow Directors, and other Outsiders
14. Conclusion.