Home » Litigation » UK: Tax Treaty Tie-breaker – Upper Tribunal’s holds Test for Place of effective Management is not the same as the “central Management and Control” Test

UK: Tax Treaty Tie-breaker – Upper Tribunal’s holds Test for Place of effective Management is not the same as the “central Management and Control” Test

www.macfarlanes.com/what-we-think/in-depth/2024/tax-treaty-tie-breaker-the-upper-tribunal-s-decision-in-haworth-v-hmrc/