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Contents

Official guidance
International Manual

INTM120000 · Company residence

  • INTM120010 · Why is company residence important?
  • INTM120020 · What this guidance replaces
  • INTM120030 · Overview
  • INTM120040 · The incorporation rule
  • INTM120050 · The incorporation rule - commencement and transitional provisions
  • INTM120060 · The case law rule - central management and control
  • INTM120070 · 'Treaty non-resident' companies
  • INTM120080 · Treaty tie-breakers and self-assessment
  • INTM120085 · Standard treaty tie-breakers
  • INTM120090 · Certificates of UK residence for companies
  • INTM120100 · Residence under foreign law
  • INTM120110 · Non-UK incorporated companies - cessation of business or liquidation
  • INTM120120 · When to question residence
  • INTM120130 · When HMRC will not usually review residence: introduction
  • INTM120140 · When HMRC will not usually review residence: limitations
  • INTM120150 · When HMRC will not usually review residence: examples
  • INTM120160 · When HMRC will not usually review residence: other cases
  • INTM120170 · When HMRC will not usually review residence: individual directors
  • INTM120180 · How to review residence
  • INTM120181 · Returns and assessments outside normal time limits: Assessing time limits
  • INTM120185 · HMRC Approach to Company Residence in response to COVID-19 Pandemic
  • INTM120190 · When to make a submission to BAI
  • INTM120200 · Statement of Practice 1/90
  • INTM120210 · Guidance originally published in the International Tax Handbook
  1. Company residence: contents
  2. Company residence: when HMRC will not usually review residence: individual directors

INTM120170 | Company residence: when HMRC will not usually review residence: individual directors

From HM Revenue & Customs · International Manual

Location of individual directors

The relevance of individual directors’ tax residence to the place of central management and control of the companies that they serve is sometimes raised as an issue. In principle it is the place from which an individual exercises central management and control that is the relevant factor for locating the residence of a company rather than the territory in which their personal tax liabilities arise.

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