Resident status determines tax residence and applies sequential tie breaker rules resolving dual residence for individuals and entities. A resident is any person liable to tax by reason of domicile, residence, place of management or similar criteria, including the State and its subdivisions, but excluding those taxable only on locally sourced income. Dual residency of individuals is resolved by, in order: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency of entities is resolved by the location of place of effective management or, if indeterminate, by mutual agreement.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Resident status determines tax residence and applies sequential tie breaker rules resolving dual residence for individuals and entities.
A resident is any person liable to tax by reason of domicile, residence, place of management or similar criteria, including the State and its subdivisions, but excluding those taxable only on locally sourced income. Dual residency of individuals is resolved by, in order: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency of entities is resolved by the location of place of effective management or, if indeterminate, by mutual agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
