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 virtue of management and control — was not a resident of either jurisdiction under the terms of the provisions and so was outside the scope of the tax treaty. HMRC now takes the view...