Residence rules determine treaty residency for individuals and entities, with tie breakers and mutual agreement resolution. Defines resident for treaty purposes as persons liable to tax by domicile, residence, place of management or similar criteria, including the State and subdivisions but excluding those taxable only on source income. Dual resident individuals are resolved by sequential tie breaker rules-permanent home, centre of vital interests, habitual abode, nationality-then mutual agreement. Dual resident non individuals are deemed resident where their place of effective management is situated, with unresolved cases referred to mutual agreement between 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.
Residence rules determine treaty residency for individuals and entities, with tie breakers and mutual agreement resolution.
Defines resident for treaty purposes as persons liable to tax by domicile, residence, place of management or similar criteria, including the State and subdivisions but excluding those taxable only on source income. Dual resident individuals are resolved by sequential tie breaker rules-permanent home, centre of vital interests, habitual abode, nationality-then mutual agreement. Dual resident non individuals are deemed resident where their place of effective management is situated, with unresolved cases referred to mutual agreement between competent authorities.
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