CIMA F1 Syllabus C. Fundamentals Of Business Taxation - Concept of Residence - Notes ^{3 / 7}

Corporate residence

This is where companies pay tax on their worldwide income

How do you know where the residence is?

Consideration of the following:

1. Place of incorporation

2. Where it is managed and controlled

3. Where it is permanently established (e.g. an office)

Double tax and deemed residence

If different tax rules mean a company seems it could have 2 places of residence, then where the effective management takes place is deemed to be the residence

Effective management is..

• where key decisions are made

• where key employees are

• where the board meets

By following this OECD deemed residence rule - means you will only be taxed in that country