Offshore obfuscation

We have a number of clients who run businesses abroad or who own holiday homes through offshore companies. (We are aware of the potential benefit in kind problems for shadow directors of the property owning companies.) As the companies are typically incorporated outside the UK the residence status of the company depends on where the central control and management of the business takes place. We can find very little guidance on how this test is applied for a business where the entire shareholding is held by one individual.
We would appreciate Taxation readers' views on whether HMRC would ever accept that a company can be controlled outside the UK if the only shareholder/director is a UK resident.
For example if three or four trips to the holiday home will be made each year and at this time whilst outside the UK all the decisions...