Some examples

Examples 1 to 8 illustrate circumstances in which HMRC would not usually seek to establish that a company is UK resident for the purposes of S5/CTA09 (see INTM120010). Enquiries will still be undertaken if they are necessary in order to fulfil the UK's obligations under a double taxation agreement. HMRC also reserves the right to enquire into any case in which arrangements appear to have been made to exploit these examples by, for example, creating the form of compliance without the substance. The exception is example 9 which illustrates a case where an enquiry may be necessary.

The following circumstances are assumed to be present in all the examples below;

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