Technical briefing: Corporate residence in light of COVID-19

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:

Our thanks to Macfarlanes LLP for allowing us to share this document.

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