https://www.taxtmi.com/caselaws?id=183788 A company's residence for income tax purposes is determined by where its central management and control are in fact exercised, not by the place contemplated in its constitution. The factual inquiry remains decisive even if the management is conducted irregularly or contrary to the company's articles. On the evidence, the boards of the subsidiaries stood aside and real control was exercised by the parent company's board in London, so the residence test was satisfied by de facto direction. The statutory provision cited was treated as consistent with that principle. en-us Mon, 02 Nov 1959 00:00:00 +0530 Tue, 21 Jun 2016 17:43:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183788 A company's residence for income tax purposes is determined by where its central management and control are in fact exercised, not by the place contemplated in its constitution. The factual inquiry remains decisive even if the management is conducted irregularly or contrary to the company's articles. On the evidence, the boards of the subsidiaries stood aside and real control was exercised by the parent company's board in London, so the residence test was satisfied by de facto direction. The statutory provision cited was treated as consistent with that principle. Case-Laws Income Tax Mon, 02 Nov 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183788