[2009] UKFTT 209 (TC)

John F Avery Jones CBE (Chairman), Roger Berner

Decision released 11 August 2009

Corporation tax – company residence – whether Dutch company was UK resident – yes – whether place of effective management was in the UK for the UK-Netherlands double taxation agreement – yes

  A company incorporated in the Netherlands was properly assessed to corporation tax on the gain arising on the disposal of its shares in a UK company since it was resident in the UK at all material times because its central control and management and place of effective management were in the UK.


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