‘Treaty Non-Resident’ companies
HMRC have updated the section of their manual entitled ‘Company residence: ‘Treaty Non-Resident’ companies’.
This section deals with dual resident companies which, under treaty tie-breakers rules, are deemed resident outside the UK. Companies which meet this criterion are known as ‘treaty non-resident’ companies.
The guidance includes an updated list of countries with whom the UK has double taxation agreements and an indication of which of these countries have residence tie-breaker rules for companies.
HMRC have also issued a new page of guidance entitled ‘Company residence: treaty tie-breakers and self-assessment’. This guidance explores the principle that a company must make a self-assessment of its residence status.