Resident status rules determine tax residence, applying permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement. Article 4 defines resident as any person liable to tax in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria, including the State and its subdivisions, but excluding persons taxable solely on source income. For dual resident individuals a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between competent authorities. For dual resident entities residence is determined by place of effective management, or otherwise by mutual agreement of the 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.
Resident status rules determine tax residence, applying permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement.
Article 4 defines resident as any person liable to tax in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria, including the State and its subdivisions, but excluding persons taxable solely on source income. For dual resident individuals a hierarchy of tie breakers applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement between competent authorities. For dual resident entities residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities.
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