Guidelines for directors—maintaining non-UK tax residence of a non-UK company
Guidelines for directors—maintaining non-UK tax residence of a non-UK company

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • Guidelines for directors—maintaining non-UK tax residence of a non-UK company

  1. 1

    Company's tax residence

    1. 1.1

      [Insert name of the company] (the Company) is resident in [insert name of the jurisdiction in which the company is intended to be tax resident]. The board of directors of the Company intends to manage the affairs of the Company to ensure that the Company remains resident for tax purposes in [insert name of the jurisdiction in which the company is intended to be tax resident] and nowhere else. Specifically, it is intended that the Company should not be or become resident for tax purposes in the United Kingdom (the UK).

    2. 1.2

      Whether or not a company incorporated outside the UK is centrally managed and controlled in the UK and therefore UK tax resident is a question of fact. It is therefore important that the directors of the Company follow procedures that ensure so far as possible that the Company does not inadvertently become tax resident in the UK. [Consequently, the board of directors resolve to adopt these guidelines detailing the procedures that the Company will follow.]

  2. 2

    Board of directors exercise strategic control

    1. 2.1

      Powers of the board of directors

    2. The directors are authorised by the

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