(Court of Exchequer) The residence of a company for tax purposes is decided by where the ‘central management and control’ is.
[1876] 1 TC 83
England and Wales
Cited by:
Adopted – De Beers Consolidated Mines Ltd v Howe, Surveyor of Taxes HL 1905
The appellant Company was registered in the Cape Colony and it’s business was mining for diamonds in mines which it possessed in South Africa, and selling the diamonds there under annual contracts to a syndicate for delivery there. The Head Office . .
Cited – Wood v Holden (Inspector of Taxes) ChD 8-Apr-2005
The parties had entered into complex share transactions for the sale of their trading business, and sought to avoid liability for capital gains tax.
Held: Gains on disposals between members of a non-resident group of companies were exempt. The . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 July 2021; Ref: scu.224772
