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 ... Summary
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.
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