Thank you for your comments.
Dean, yes the company is incorporated in the UK but don't you have to have your central management and control in the UK also to be UK resident for tax purposes? Also, there is something in tax bulletin 62 which talks about companies acting as agents not being able to obtain a residency certificate.
Hashman, the Italian company is dealing with the UK company as undisclosed agent for the BVI company. So yes, from their point of view, they are dealing with a UK company. But why is this a worry? The UK company takes commission from the sales and then passes the remainder on to the BVI company. Ignoring any transfer pricing issues, which have already been addressed, is there a problem obtaining a certificate of UK residency for this type of arrangement?
Thanks a lot.