Of interest to those working in non-domiciled companies
One of the issues which we regularly receive questions from members about is the implications for the tax residence of a company when they have to dial in to a board meeting and how this should be recorded. This has been exacerbated in the light of the travel restrictions associated with COVID-19.
Macfarlanes LLP have produced a very helpful article on this issue, which they have kindly allowed us to share with our members.
Key points include:
- non-UK companies are at risk of becoming UK tax residents if travel restrictions prevent key decision makers from leaving the UK
- other companies may find it difficult to sustain their intended place of tax residence (e.g. for treaty purposes) if directors are unable to travel to meetings
- virtual meetings can be a practical solution to travel disruption but are a source of tax risk
- as COVID-19 disruption may last for some time, companies should consider now what practical steps they can take to manage these risks
The full analysis can be found at: www.macfarlanes.com/what-we-think/in-depth/2020/corporate-residence-in-light-of-covid-19/
Our thanks to Macfarlanes LLP for allowing us to share this document.
