Tax residence tie-breaker rules determine which state taxes an individual when residency conflicts arise between contracting states. Defines a resident of a Contracting State as any person liable to tax by domicile, residence, place of management or similar criterion. For individuals resident of both States, residence is determined by a hierarchy: permanent home; if both, centre of vital interests; if indeterminate or no permanent home, habitual abode; if habitual abode does not resolve, nationality; if still unresolved, mutual agreement by competent authorities. For non-individuals resident of both States, residence is where the entity's place of effective management is situated.
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 residence tie-breaker rules determine which state taxes an individual when residency conflicts arise between contracting states.
Defines a resident of a Contracting State as any person liable to tax by domicile, residence, place of management or similar criterion. For individuals resident of both States, residence is determined by a hierarchy: permanent home; if both, centre of vital interests; if indeterminate or no permanent home, habitual abode; if habitual abode does not resolve, nationality; if still unresolved, mutual agreement by competent authorities. For non-individuals resident of both States, residence is where the entity's place of effective management is situated.
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