What happens if my company is dual resident under two countries' rules?

Older UK treaties often broke a tie by reference to the place of effective management alone. Many current treaties, following the OECD Multilateral Instrument, instead require the two tax authorities to agree the residence by mutual agreement procedure, considering management, incorporation and other facts together.

Until agreement is reached, treaty benefits such as reduced withholding rates can be denied, so an unresolved dual residence position is not just theoretical: it can cost real money on cross-border payments in the meantime.

Map both countries' residence tests against how the company is actually run, not how it looks on paper, and get advice in both jurisdictions before relying on treaty relief, since UK advice alone cannot confirm the foreign law position.

Where the risk is real, some owners simplify by incorporating locally instead of using a UK company, or by moving genuine board decision-making clearly into one country and keeping evidence of it.

Our fixed monthly packages for a UK limited company start at £89 plus VAT and run to £169 and £289 plus VAT as bookkeeping, VAT, payroll and reporting are added. One-off filings are sold at fixed prices, and the Companies House fees we pay for you are charged at cost with no VAT added. Overseas owners are quoted on exactly the same published prices as UK-resident clients.

Rates, thresholds and deadlines here reflect the 2026/27 UK position and current Companies House and HMRC guidance. Check GOV.UK, or ask us, before relying on them for your own company.