Court of Appeal decides that Jersey companies were UK tax resident
By EsqSocial Corporation 28/12/20
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the UK for tax purposes by reason of being centrally managed and controlled in the UK....
By: Proskauer - Tax Talks