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View the related Tax Guidance about Dual residency

Residence of companies

Residence of companiesThe concept of residence is important because corporation tax is chargeable on the worldwide profits of any company that is resident in the UK. The liability may be reduced by exemption or relief under a double taxation agreement or by unilateral relief. Non-UK resident companies are only liable to UK corporation tax on certain sources of income, such as profits attributable to a trade of dealing in or developing UK land, for example. This guidance note outlines when a company (or an entity treated as a company for UK tax purposes) will be treated as resident in the UK. The UK position is set out first and then the tie-breaker provisions which may apply if another jurisdiction also sees that company as resident for tax purposes in that other jurisdiction. See the Entity classification guidance note for a discussion of what HMRC view as a company.There may also be tax consequences when the residence of a company changes. See the Inbound migration and Outbound migration guidance notes. A company will be treated as resident in the UK if it is either incorporated in the UK (the ‘statutory test’ ― CTA 2009, s 14) or centrally managed and controlled in the UK (the ‘case law test’).Note that a company that is not resident in the UK for tax purposes may still be subject to UK tax (whether directly of indirectly). See the Non-UK companies subject to UK tax guidance note for further commentary on this and the relevant