What HMRC and courts look at
The test asks where real strategic control sits, not day-to-day management. Case law such as De Beers Consolidated Mines looks past the country of incorporation to where the board actually meets, deliberates and makes decisions that matter, rather than where minutes say they happened.
A rubber-stamp board that approves decisions already made informally elsewhere does not fix the place of central management and control there; substance in decision-making is what counts, not the location on paper.






