This is a requirement imposed by the EU under State Aid rules. The test is ‘completely different and separate’ from that of ‘central management and control’ relevant in determining whether a company is resident in the UK (SP 4/00, para. 33).
As no specific EC guidance is available on the meaning of strategic and commercial management, the Revenue has stated it would adopt a common-sense interpretation, taking into account the various different strands of management activity that can be carried out in respect of a ship. The Revenue is happy to provide guidance on this test as part of the clearance procedure (SP 4/00, para. 34).