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In this episode of The UK Tax Podcast, John Kavanagh examines the rules regarding UK corporate tax residenceand the approach taken by HMRC. He explains the UK’s central management and control test, how HMRC has challenged offshore structures, and the role of double tax treaties in resolving residence disputes. The episode also explores the growing use of the mutual agreement procedure in modern treaties and touches on the relevance of permanent establishment rules for non-resident companies. Along the way, John briefly touches on recent media reports concerning Roman Abramovich’s offshore companies and their potential UK tax implications.

Tune in for expert insights into the complexities of corporate tax residence and what businesses should consider when structuring their international operations.