Resident status under the DTAA sets tie breaker rules for dual residency, prioritizing permanent home and vital interests. The Convention defines resident of a Contracting State as any person liable to tax therein by reason of domicile, residence, place of management or ... Summary
Resident status under the DTAA sets tie breaker rules for dual residency, prioritizing permanent home and vital interests.
The Convention defines resident of a Contracting State as any person liable to tax therein by reason of domicile, residence, place of management or similar criteria, excluding persons taxed only on in state sources or capital. Dual residency for individuals is resolved by a sequential tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. For entities, residence is determined by the location of the place of effective management, with unresolved cases referred to the competent authorities for mutual agreement.
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