Company residence (UK corporation tax)
A company incorporated in the UK is generally UK resident for corporation tax, subject to statutory and treaty exceptions. A company incorporated elsewhere may be UK resident where its central management and control is actually exercised in the UK. The facts and relevant exceptions must be considered; registered office or operations alone do not necessarily settle the central-management test.
Worked example
A company incorporated outside the UK has its real central management and control exercised by its board in the UK. Assuming no applicable exception changes the result, it is UK resident for corporation tax.
Common mistake
Assuming incorporation abroad always prevents UK residence or equating day-to-day operations automatically with central management and control.
Where it appears in your exams
| Qualification | Exam | Relationship | Period |
|---|---|---|---|
| ACCA | TX (UK) | Direct | June 2026–June 2027 |