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Legal testUK · IE · UAEReviewed October 2026
The place where the key management and commercial decisions needed to run a company are, in substance, made. Many double taxation agreements use it as the tie-breaker to settle a single country of residence when a company would otherwise be resident in two.
It is close to, but not identical to, the UK central management and control test, and turns on where real decisions are taken rather than where board meetings are formally held.
A definition of an established legal or tax concept for general information. It is not advice on any individual situation.
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