What factors determine a corporation’s tax residency?

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The determination of a corporation's tax residency is primarily based on factors such as the place of incorporation and where the corporation's management and control occur. The place of incorporation refers to the jurisdiction in which a corporation is legally registered. This is crucial as different jurisdictions have distinct tax laws and regulations that apply to corporations.

Furthermore, management and control typically relate to where the board of directors meets and makes decisions regarding the business's operations. In many tax systems, a corporation is considered a tax resident of the place where its effective management occurs. This means that if a corporation is incorporated in one location but is effectively managed from another, the tax authorities may look at both aspects to determine residency.

While the location of shareholders and board meetings can have relevance, they do not carry the same weight as the place of incorporation and management. Annual revenue, profit margins, and the type of industry or sector might influence the level of tax obligations but do not define tax residency. Thus, focusing on both the place of incorporation and actual management is key to understanding how tax residency is established.

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