[9 January 1990]

1. Residence has always been a material factor, for companies as well as individuals, in determining tax liability. But statute law has never laid down comprehensive rules for determining where a company is resident and until 1988 the question was left solely to the Courts to decide. Section 66 FA 1988 introduced the rule that a company incorporated in the UK is resident there for the purposes of the Taxes Acts. Case law still applies in determining the residence of companies excepted from the incorporation rule or which are not incorporated in the UK.

A. The Incorporation rule

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