Tax residency tie breaker rules determine exclusive residency through home, centre of interests, abode, nationality, or mutual agreement. Article 4 defines resident of a Contracting State as any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those liable only on source income in that State. For dual resident individuals, residency is determined by a sequence of tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities resolve by mutual agreement. For entities other than individuals, residency is determined by the place of effective management, with unresolved cases settled by the competent authorities under the mutual agreement process.
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 tie breaker rules determine exclusive residency through home, centre of interests, abode, nationality, or mutual agreement.
Article 4 defines resident of a Contracting State as any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those liable only on source income in that State. For dual resident individuals, residency is determined by a sequence of tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and failing those the competent authorities resolve by mutual agreement. For entities other than individuals, residency is determined by the place of effective management, with unresolved cases settled by the competent authorities under the mutual agreement process.
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