UK Corporate Tax Residence and HMRC’s Approach
Recorded March 2025 · Episode 7 · 10:02
In this episode I examine when a company is resident in the United Kingdom for tax purposes and how HMRC approaches the question. I explain the central management and control test that sits alongside the incorporation rule, what the case law tells us about where that control is actually exercised, and how HMRC has challenged offshore structures where the substance does not match the form. I also draw out the practical implications for the boards of overseas companies with UK connections, and the steps that help ensure the residence position is robust.
This podcast is not a substitute for professional advice.