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Company residence

HMRC published new draft guidance to be included in its International Manual, following discussions at its Business Tax Forum, on the situations

HMRC published new draft guidance to be included in its International Manual following discussions at its Business Tax Forum on the situations in which HMRC will not usually review a company's residence status. HMRC provided eight examples of such situations but pointed out that it reserved the right to enquire into any case where arrangements appear to have been made to exploit the examples ‘by for example creating the form of compliance without the substance’.

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