INTM120020 - Company Residence

Company Residence: what this guidance replaces

This guidance re-publishes the paragraphs on company residence which were previously found in the Company Tax Manual from CT3365 onwards. There are a small number of changes to the ordering of the material and a number of minor amendments and additions.

We have also re-published the material on company residence which was previously found in the International Tax Handbook from ITH300 onwards. This can now be found at INTM120150. This material remains relevant if you are considering the central management and control test.

For ease of reference, you will find the text of Statement of Practice 1/90 'Company Residence' at INTM120140.

This guidance also includes references to articles which appeared in Tax Bulletin 14 (December 1994) and Tax Bulletin 62 (December 2002). You should refer to the Tax Bulletins for the full text of those articles.