ATXP6 UK
Syllabus A4. Corporation Tax A4a. The scope of corporation tax

A4a. Residency of a company

Syllabus A4a)

E1 The scope of corporation tax

Who pays UK corporation tax?

How is UK residency determined for companies?

A company is resident in the UK if:

  1. It has been incorporated in the UK, for example. K Ltd. or B plc.

  2. It is centrally managed and controlled in the UK for example, M. Inc. which was incorporated overseas has majority of its board meetings held in the UK, and most of its directors are resident in the UK.

Illustration

B Inc. was incorporated in Barbados. 

All of the company's board meetings are held in the UK. 

Will the company be considered to be UK resident and therefore have to pay UK Corporation Tax?

  • Solution

    Yes, the company will be considered to be UK resident and therefore pay UK Corporation Tax.

    This is because, even though it has been incorporated overseas, it is centrally managed from the UK.