Tax residency rules determine treaty residence and tie breaker criteria, affecting where individuals and entities are deemed resident. The provision defines resident of a Contracting State as any person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income, and sets hierarchical tie breaker rules for dual-resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and for non-individuals resolves dual residence by the State of the place of effective management, or by mutual agreement if that place cannot be determined.
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.
Tax residency rules determine treaty residence and tie breaker criteria, affecting where individuals and entities are deemed resident.
The provision defines resident of a Contracting State as any person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income, and sets hierarchical tie breaker rules for dual-resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and for non-individuals resolves dual residence by the State of the place of effective management, or by mutual agreement if that place cannot be determined.
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