Company residence: A German individual acquired the entire shares in a company incorporated and resident in the Netherlands. In April 1994, he moved to a London residence. The First-Tier Tribunal held that the company was UK resident, as its central management and control was in the UK.
(Laerstate BV v Revenue & Customs  UKFTT 209 (TC)).
UK companies seeking to minimise tax bills by relocating abroad would face years of scrutiny by HMRC to ensure that senior management decisions have genuinely relocated. Dave Hartnett, permanent secretary at HMRC, warned that, even if board meetings are held outside the UK among non-resident directors, a company could be deemed resident if evidence suggested key decisions were taken from within the UK.