Can someone clarify the usual analysis done by the tax office when: - The company is registered in tax-haven (H) - Owners are resident in countries A, B, C, and D. No CFC rules are in effect as ownership is less than whatever rules those countries have. Then these are the two questions I have: a) When owner resident in country A works for the company inside country A, will the "place of business" test make it (partially) tax-resident? What if the owner is a consultant working at a customer's site? b) Consider owner resident in country A working for the company while on vacation in country V. Could there ever be a "place of business" in country A if no work happens in country A, but a resident of country A who has some control over the company works for the company (but outside of country A)? Thanks!