If you already have a UK company but you require a Tax Residence Certificate (TRC) in order to claim relief under the tax treaty that the UK may have with your home country, then we could assist. In some circumstances HMRC, the UK tax authority, may refuse to issue a TRC if it believes that the conditions of either UK domestic law or the international DTA are not being met. This might arise for instance if HMRC take the view that the company is not being “centrally managed or controlled” from the UK or “effective management and control” does not reside in the UK. In such cases RKG Consulting has had success in persuading HMRC that such conditions are being met and this has resulted in the TRC being issued. Where we are involved regarding the set-up of the UK company we can structure affairs so that this problem does not arise in the first instance.
