[SkyAndSand]

Yes, that is a good point which applies to a lot of high-tax countries. If you are a single company founder and run a company in jurisdiction B from country A then country A will usually have provisions that the company will be resident in A.

The question that I am wondering about is more like - you have four founders with 25% each who live in four different countries.

Where is the company resident in that situation?

[tluyben2]

I have had this issue in NL and ES; both tax offices accepted that the the decision making was not in respectively NL or ES because most of the decision making (directors and shares) were not in either country.