Residence tie breaker rules determine tax domicile by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement. Article 4 defines tax residence by reference to each Contracting State's domestic law and sets hierarchical tie breaker rules for dual residencies: for individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement by competent authorities; for non individuals-the place of effective management determines treaty residence.
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 tie breaker rules determine tax domicile by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement.
Article 4 defines tax residence by reference to each Contracting State's domestic law and sets hierarchical tie breaker rules for dual residencies: for individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement by competent authorities; for non individuals-the place of effective management determines treaty residence.
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