Concept of Residence

NotesQuiz

Corporate residence

This is where companies pay tax on their worldwide income

How do you know where the residence is?

Consideration of the following:

  1. Place of incorporation

  2. Where it is managed and controlled

  3. Where it is permanently established (e.g. an office)

Double tax and deemed residence

If different tax rules mean a company seems it could have 2 places of residence, then where the effective management takes place is deemed to be the residence

Effective management is..

  • where key decisions are made

  • where key employees are

  • where the board meets

By following this OECD deemed residence rule - means you will only be taxed in that country

NotesQuiz