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If a payment is made or accrued to a BVI incorporated company whose directors are resident in Hong Kong and its central management and control is in Hong Kong, should the BVI incorporated company be regarded as a non-resident?

If a payment is made or accrued to a BVI incorporated company whose directors are resident in Hong Kong and its central management and control is in Hong Kong, should the BVI incorporated company be regarded as a non-resident?

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Dalton
 

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A BVI incorporated company should not be regarded as a non-resident if its directors are resident in Hong Kong and its central management and control is in Hong Kong.

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Oliver
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