Tax residence rules: sequential tie breaker criteria determine residency and resolve dual residence by mutual agreement. Defines resident as a person liable to tax in a Contracting State by domicile, residence, place of management or similar criteria, excluding persons taxed only on source income. Dual residency for individuals is resolved by sequential tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency for non individuals is resolved by place of effective management, with disputed claims to be settled by mutual agreement of competent authorities.
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 residence rules: sequential tie breaker criteria determine residency and resolve dual residence by mutual agreement.
Defines resident as a person liable to tax in a Contracting State by domicile, residence, place of management or similar criteria, excluding persons taxed only on source income. Dual residency for individuals is resolved by sequential tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities. Dual residency for non individuals is resolved by place of effective management, with disputed claims to be settled by mutual agreement of competent authorities.
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