关于非英国收入纳税的讨论
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在政府官网上关于税收的说明中,有
If your company is not classed as UK resident for tax purposes but has an office or branch here, it only pays Corporation Tax on profits from its UK activities.
所以我查了下到底哪些情况是不会被视为英国公司,最后在HMRC先到了这个
The place of central management and control as a test of residence is now relevant only to
companies not incorporated in the UK and
UK incorporated companies which qualify for exception to the incorporation rule, so long as their place of central management and control is outside the UK
所以,只要一个英国公司,实际控制不在英国,那它应该被视为非英国税收对象 -
另外还有
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.