Corporate residence is determined by reference to the location of the central management and control of the business of a company. There are no specific provisions within the law, and, as such, common law principles established by the courts are generally applied in determining residence. The place of incorporation is regarded as merely one of the factors to be taken into account in determining where central management and control are located.
Permanent establishment (PE)
There are no specific provisions in the legislation dealing with PEs; however, common law principles are generally applied.