What is the Central Management and Control test?

Central Management and Control (CMC) is the common-law test for where a company is genuinely run. A company is tax-resident wherever its highest-level strategic decisions are actually made. If you run a UK company entirely from abroad, that country can claim it is resident there too, creating dual residence that a tax treaty resolves.

By substance, not paperwork. Tax authorities look at where the real strategic decisions are taken, where directors meet and decide, and who genuinely controls the company, rather than the registered office address.

Yes. A UK-incorporated company managed from abroad can be resident in both, with a double-tax treaty's tie-breaker deciding which country has the primary claim, usually based on where effective management sits.

Keep genuine strategic decision-making in the UK, hold board meetings there where possible, and consider UK-resident co-directors. Document where and how key decisions are made.