In our latest Axis Newsbite, we are pleased to share a thought-leadership insight from our Managing Director, Mr. Assad Abdullatiff, exploring the critical distinction between Place of Effective Management (POEM) and Central Management and Control (CMC), a longstanding source of debate in international tax law.

In the recent case of Haworth v HMRC [2025] EWCA Civ 822, the English Court of Appeal has provided much-needed clarity—ironically, in a case that centred around the use of Mauritius to shift tax residence. The decision confirms not only that POEM and CMC are different tests, but also that merely engineering changes in form, without a shift in substantive control, will not succeed.

Click Here to read the full insight.

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