Tax residency rules determine the primary State for taxation when an individual or entity is resident in both Contracting States. Defines Resident of a Contracting State as persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxed only on source income in that State. For individuals with dual residency, the tie breaker sequence is permanent home, centre of vital interests, habitual abode, nationality, and then mutual agreement. For non individuals with dual residency, residence is the place of effective management, or otherwise resolved 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 residency rules determine the primary State for taxation when an individual or entity is resident in both Contracting States.
Defines Resident of a Contracting State as persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxed only on source income in that State. For individuals with dual residency, the tie breaker sequence is permanent home, centre of vital interests, habitual abode, nationality, and then mutual agreement. For non individuals with dual residency, residence is the place of effective management, or otherwise resolved by mutual agreement of competent authorities.
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