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by codehotter 3448 days ago
Good question. I'm not a lawyer; I assume edge cases will be decided by the relevant tax authorities. Speculating here, but if there's a single place where management decisions are made, say where the CEO lives, the corporation might be tax resident there. Otherwise, they might decide to tax you in place of incorporation.

For such a company, what address would it have? Maybe where you place its headquarters has some significance too.

1 comments

IANAL, but my understanding is that common law jurisdictions generally consider a corporation to be resident wherever "management and control" is exercised; corporations which are at risk of being considered resident in a jurisdiction where they do not want to be considered resident normally ample evidence of the locations of their board meetings and the physical presence of board members in order to prove that control is not being exercised within the avoided jurisdiction.