Keyword

corporate residence

2 decisions turning on corporate residence.

Cogefin (Bermuda) Limited & Anor v The Commissioners for HMRC

Tax LawFirst-tier Tribunal (Tax)25 Jul 2025[2026] UKFTT 1108 (TC)Added 31 Jul 2026

Cogefin (Bermuda) Limited was incorporated in Bermuda in February 1996 as an exempted company wholly owned by the Poole Family Trust, of which Mr Giuseppe Ciardi was the economic settlor and beneficiary. It was funded with some…

Vincent Alan Snell v Her Majesty's Revenue & Customs

Tax LawSpecial Commissioners of Income Tax5 Apr 2006Added 6 Aug 2026

Mr Vincent Snell, who had run the Stockport rubber products manufacturer Sovereign Rubber plc since his father's death in 1972, resolved by 1994 to sell the company, partly in order to acquire an estate in Scotland and run a…

capital gains tax tax-appeals share transfer closure-notice main purpose test