DT16803 | Double Taxation Relief Manual: Sierra Leone: 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 dual resident individuals will not be able to obtain any benefits available under 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 Sierra Leone, claims to be a resident of Sierra Leone, the case should be referred to Business International before enquiries are raised on the matter.