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Further to the guidance provided by HMRC at the beginning of April, please find below links to updated guidance on HMRC’s approach to company residence and permanent establishments in response to COVID-19 Pandemic. The updates involve the addition of two paragraphs at the bottom of INTM120185 and one paragraph at the bottom of INTM261010.

HMRC Manual at INTM20185 now clarifies 'We do not consider that a company will necessarily become resident in the UK because a few board meetings are held here, or because some decisions are taken in the UK over a short period of time. HMRC guidance makes it clear that we will take a holistic view of the facts and circumstances of each case.'