Generally, however, where doubts arise about a particular company's residence status, HM Revenue & Customs adopt the following approach:

They first try to ascertain whether the directors of the company in fact exercise central management and control.
If so, they seek to determine where the directors exercise this central management and control (which is not necessarily where they meet).
In cases where the directors apparently do not exercise central management and control of the company, HM Revenue & Customs then look to establish where and by whom it is exercised.