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Ensuring Non-UK Tax Residence - The Laerstate Case

November 12, 2009
SRZ Client Memorandum


A recent case (Laerstate BV v Revenue & Customs [2009] UKFTT 209 (TC)) in the UK’s First Tier Tribunal (the “Tribunal”) has demonstrated that it is not possible to ensure that a company is not treated as UK tax resident merely by complying with administrative rules and procedures, but that attention must always be given to the substantive arrangements put in place for the management of the business of the company.

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