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 ... Summary
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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