CG42303 | Migration of companies: company residence: from 30/11/93
From HM Revenue & Customs · Capital Gains Manual
FA94/S249
From 30 November 1993 onwards FA94/S249 introduced a rule that all `treaty non-resident’ companies, see CG42321, are not resident for all taxation purposes. The incorporation rule still applies. As a result
all companies incorporated in the UK are resident here except-
those exempted from the incorporation rule by FA88/SCH7
and
`treaty non-resident’ companies.
all companies incorporated outside the UK whose central management and control is exercised in the UK are resident here except those which are `treaty non-resident’.