A dual-resident company is generally considered to be one which, in any accounting period, is both resident in the UK for UK tax purposes, and chargeable to non-UK tax in a territory outside the UK under the laws of that territory. This could, for example, be because the company derives its status as a company from those laws; because its place of management is in that territory; or indeed for any other reason.

Where a company is dual resident, most double taxation agreements (DTAs) contain a tie-breaker clause which determines in which country the company is to be treated as resident for the purposes of the agreement (see below).

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