Company residence
Case law rule
Ceasing to be UK resident
Central management and control
Central management and control test
Cessation of business
Change of
Chargeable gains
Controlled foreign companies
Determination, rules for
Disposal of business
Disposal of shares as settlors of non-resident settlements
Domicile
Double taxation agreements
Generally
Non-resident under
Double taxation agreements, tie-breaker clause
Dual residence
Dual resident companies
European Company (SE) transfer of registered office to the UK
European Cooperative Society (SCE) transfer of registered office to the UK
Generally
Implications of UK residence
Incorporated in the UK
Incorporation
Incorporation rule
Migration of companies
Non-resident companies
Ordinary residence
Permanent establishment
Generally
Place of effective management company incorporated in the Netherlands
Rules for determining
Case law rule
Central management and control test
Change of residence
Companies treated as non-resident, tie-breaker rule
Domicile
Dual resident companies
Generally
Implications of residence
Incorporation rule
Ordinary residence
Transfer
Abroad, consent
Between member states
Reduction in capital tax
Unrealised capital gains, freedom of establishment
Transfer of assets abroad
Winding up
