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
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