Model Convention with respect to residency of individuals. Where a company is a resident of both Contracting States, such company shall not be treated as a resident of either Contracting State for purposes of its claiming the benefits of the tax treaty. Where a person other than an individual or a company is a resident of both Contracting States, the competent authorities of the Contracting States shall by mutual agreement endeavor to determine the mode of application of this Convention to that person. Therefore, domestic taxation will continue as normal until an agreement is reached. In the United Kingdom In the United Kingdom for companies A company is generally treated as resident in the United Kingdom for tax purposes if it is incorporated in the United Kingdom or, if the company is not incorporated in the United Kingdom, if its central management and control are exercised in the United Kingdom. "Central management and control" refers to the highest level of oversight, usually as exercised by the board, rather than day-to-day management. In the United Kingdom for individuals Schedule 45 of the Finance Act 2013 sets out the rules for determining whether individuals are resident or not resident in the UK. This is known as the statutory residence test. The rules are complicated and the following is only a brief outline. The Test takes into account the amount of time the individual spends or works in the UK and the connections the individual has with the UK. The Test is split into automatic overseas tests, automatic UK tests, and sufficient ties test. There are additional rules for residence of deceased persons and split years (years of arrival and departure). An individual who spends more than 183 days in the UK in a tax year is a UK resident. If the individual fulfills this, there is no need to consider any other tests. If this limb is not fulfilled, the individual will be resident in the UK for a tax year and at all times in the tax year if they do not meet any of the automatic overseas tests, and they meet one of the automatic UK tests or the sufficient ties test. An individual will not be resident in the UK for the tax year if they do meet one of the automatic overseas tests, or they do not meet any of the automatic UK tests or the sufficient ties