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UK Change of View on the Interpretation of Residence Articles Regarding Dual-Resident Companies in Sixteen Tax Treaties

|Treaty Development|United Kingdom-Antigua and Barbuda-Beliz ...
United Kingdom-Antigua and Barbuda-Belize-Brunei-Greece-Grenada-Guernsey-Isle Of Man-Jersey-Kiribati-Malawi-Montserrat-Myanmar-Sierra Leone-Solomon Islands-Saint Kitts and Nevis-Tuvalu

On 24 June 2022, UK HMRC published an updated policy paper setting out a change of view on the interpretation of the residence articles in sixteen tax treaties in relation to dual-resident companies. As explained in the paper, HMRC's previous view was that a dual-resident company — for example, a company resident in the UK by virtue of incorporation and resident in the other jurisdiction by vi…

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