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HMRC changes policy on tax treaty company residence tie-breakers

HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.

HMRC has revised its interpretation of the residence articles in 16 double taxation agreements taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously HMRC regarded dual-resident companies as outside the scope of the treaties. See www.bit.ly/1NHeXTk. 

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