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This content covers guidance applicable to the coronavirus (COVID-19) pandemic.

With directors of companies potentially stranded abroad due to coronavirus (COVID-19), but business still needing to continue, board meetings may be held with directors joining remotely. This could potentially impact on where the central management and control (or effective management) of those companies is located.

While most UK incorporated companies are resident in the UK regardless of the location of central management and control, a few companies that are usually UK resident (for example, those incorporated outside the UK but managed in the UK) still fall under the central management and control case law test for residence¹.

Central management and control is often a question of fact and will depend on a number of criteria. A significant factor in assessing this test can be the location of board meetings. However, HMRC guidance