A non-UK incorporated company becomes UK tax resident under the UK's domestic residence rules if it becomes centrally managed and controlled in the UK. Although some non-UK incorporated companies may wish to become UK tax resident, many do not.

This Checklist:

1. •

   summarises key guidelines that a non-UK incorporated company's board should aim to follow in order to reduce the risk that the non-UK incorporated company may become centrally managed and controlled, and therefore tax resident, in the UK—this Checklist may serve as a reminder for the directors

2. •

   is relevant to non-UK incorporated companies that have some connection to the UK that gives rise to the risk that it may become UK tax resident, such as a non-UK incorporated company:

   1. ◦

      where at least one (if not more) of its directors is/are UK tax resident

   2. ◦

      that has its shares or debt securities listed on a recognised stock exchange in the UK, such as the Main Market of the London Stock Exchange, or admitted to trading on a UK recognised growth market,