UK company residence

A company that is tax resident in the United Kingdom (UK) is generally subject to UK corporation tax on its worldwide profits unless it has made a valid foreign branch exemption election under which the profits of its non-UK permanent establishments (PEs) are, subject to exceptions, exempt from UK corporation tax.

Even if a company is not tax resident in the UK, it may still be subject to UK taxes, including UK corporation tax, as explained in Practice Note: When does the UK tax non-resident companies?

UK domestic rules on corporate tax residence

Under the UK’s domestic rules, a company is tax resident in the UK if it is:

•
incorporated in the UK, or
•
centrally managed and controlled in the UK, which is a question of fact

The meaning of central management and control derives from case law. It is directed at the highest level of control of a company’s business. It is a question of fact who exercises this control and where it is exercised.

For more information, see Practice Note: When a company is UK tax resident.

Dual tax residence

Other

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