Andrew Watters and Jonathan Levy of LevyWatters consider how one can identify the abode of central management and control following the Court of Appeal's judgment in Wood v Holden
The Court of Appeal has recently given its decision on company residence in the case of Wood v Holden[2006] EWCA Civ 26 (Wood). In HMRC's well publicised attack on avoidance offshore structures are a regular target with the argument that a company registered offshore should be treated as UK-resident for tax purposes by virtue of its central management and control. The decision to litigate Wood will have been with one eye on providing case law ammunition for future anti-avoidance...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Andrew Watters and Jonathan Levy of LevyWatters consider how one can identify the abode of central management and control following the Court of Appeal's judgment in Wood v Holden
The Court of Appeal has recently given its decision on company residence in the case of Wood v Holden[2006] EWCA Civ 26 (Wood). In HMRC's well publicised attack on avoidance offshore structures are a regular target with the argument that a company registered offshore should be treated as UK-resident for tax purposes by virtue of its central management and control. The decision to litigate Wood will have been with one eye on providing case law ammunition for future anti-avoidance...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
