In Cogefin (Bermuda) Ltd & Ciardi v HMRC [2026] UKFTT 1108 (TC) the First-tier Tribunal considered whether Cogefin, a Bermuda-incorporated company, was resident in Bermuda or in the United Kingdom for corporation tax purposes during the accounting periods from 1999 to 2017. Cogefin had been incorporated in 1996 and was owned by the Poole Family Trust, of which Mr Giuseppe Ciardi was the economic settlor and beneficiary. The company had Bermudian-resident directors, but HMRC contended that Mr Ciardi exercised central management and control from the UK. After an investigation and a disclosure made through the Liechtenstein Disclosure Facility, HMRC issued assessments for corporation tax, imposed penalties for failure to notify chargeability and issued a personal liability notice to Mr Ciardi.