CG42300 | Migration of companies: company residence
From HM Revenue & Customs · Capital Gains Manual
The rules determining where a company is resident for taxation purposes depend on theperiod under consideration. Depending on what period you are dealing with you will need toconsider one or more of the following.
Where the central management and control of the company is exercised.
Where the company is incorporated.
Whether the company is `treaty non-resident’, see CG42321.