HMRC has published new draft guidance on situations where it will not usually review a company's residence status
HMRC has published new draft guidance on situations where it will not usually review a company's residence status (see www.lexisurl.com/gFVtq). It is important to remember that the purpose of the draft guidelines is to identify low-risk situations rather that to draw the lines in more challenging scenarios. The assumptions underlying the guidance ensure that the guidance which at first sight appears to solve some tricky issues really only serves to reassure low risk companies that accidental or occasional UK-based decision making will not turn them into high-risk residence cases.
Two assumptions are worthy of particular note. The first is the restriction of the guidance to cases where the overseas company is a trading company (the location of which is likely to be driven by commercial imperatives rather than tax)...
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Home >Articles > Corporate residence following HMRC’s revised guidance
Corporate residence following HMRC’s revised guidance
HMRC has published new draft guidance on situations where it will not usually review a company's residence status
HMRC has published new draft guidance on situations where it will not usually review a company's residence status (see www.lexisurl.com/gFVtq). It is important to remember that the purpose of the draft guidelines is to identify low-risk situations rather that to draw the lines in more challenging scenarios. The assumptions underlying the guidance ensure that the guidance which at first sight appears to solve some tricky issues really only serves to reassure low risk companies that accidental or occasional UK-based decision making will not turn them into high-risk residence cases.
Two assumptions are worthy of particular note. The first is the restriction of the guidance to cases where the overseas company is a trading company (the location of which is likely to be driven by commercial imperatives rather than tax)...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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