Residence determination under DTAA: tie breaker rules allocate tax residence by home, centre of vital interests, abode, nationality. A resident of a Member State is any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on in state source income. Where an individual is resident in more than one Member State, residency is determined by: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between Competent Authorities. For non individuals resident in multiple Member States, residence is determined by 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.
Residence determination under DTAA: tie breaker rules allocate tax residence by home, centre of vital interests, abode, nationality.
A resident of a Member State is any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on in state source income. Where an individual is resident in more than one Member State, residency is determined by: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between Competent Authorities. For non individuals resident in multiple Member States, residence is determined by place of effective management, or by mutual agreement if that place cannot be determined.
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