DT11254 | Double Taxation Relief Manual: Kiribati: resident

An individual who is a resident of one country and also resident in the other country is not a resident of either country for the purposes of the agreement (see INTM154020). Such a dual resident individual will not be entitled to any benefits provided by the agreement.

A company is a resident of the country in which it is taxed as a resident either because it is managed and controlled in that country or because it is incorporated there. Where a company which is incorporated in the United Kingdom, but managed and controlled in Kiribati, claims to be a resident of Kiribati, no claim should be admitted and the case should be referred to Business International.