Not necessarily only where it is registered. Many countries also treat a company as resident where it is managed and controlled. So a company registered in one country but run by someone living in another can end up claimed by both.
What decides it
- Where the board really makes its decisions, not just where meetings are minuted.
- Where the directors live, and who in practice runs the company.
- Whether the company has real activity where it says it is based: people, premises and decisions.
When two countries claim the company
Under many treaties now, the two tax authorities must agree where a dual-resident company is resident, looking at where it is managed, where it was incorporated and other factors. If they don't agree, the company may get no treaty relief.
Reporting
A company with mainly investment income is looked through under CRS, so its owners are reported anyway. See What does CRS report about me?
An example
Lina sets up a holding company in a low-tax jurisdiction and makes every decision from her home in another country. Her home country may treat the company as managed there, and tax its profits as if it were a local company.
Quick questions
Does a local director solve it?
Not if the decisions are really made elsewhere. The director has to make them.
Can this happen to a UAE company?
Yes. A UAE company run day to day from another country can be claimed by that country too.
Sources: BCAJ: Dual resident entities under Article 4 of the MLI; UAE Ministry of Finance: CRS guidance notes.
General information as at October 2026, not advice. The examples are fictional and simplified, and the rules have conditions and exceptions not covered here. Take advice on your own circumstances, in each country involved, before acting.