435. Companies.

There are two tests in determining a company's residence:


    (1)     the place of incorporation; and


    (2)     the place of central management and control.

As a general rule, the incorporation test applies to companies incorporated in the United Kingdom1 and the control and management test applies to companies incorporated elsewhere.

A company which is incorporated in the United Kingdom is regarded for the purposes of the Corporation Taxes Acts2 as resident there; and accordingly, if a different place of residence is given by any rule of law, that place is no longer to be taken into account for those purposes3.

A company which