Residence tie-breaker rules determine which State an individual is treated as resident for tax treaty purposes. The provision defines a resident of a Contracting State as any person treated as resident under that State's tax law and provides hierarchical tie breaker rules for dual resident individuals-permanent home, centre of vital interests, habitual abode, and nationality with mutual agreement as a final remedy-and for non individuals determines residency by place of effective management.
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 which State an individual is treated as resident for tax treaty purposes.
The provision defines a resident of a Contracting State as any person treated as resident under that State's tax law and provides hierarchical tie breaker rules for dual resident individuals-permanent home, centre of vital interests, habitual abode, and nationality with mutual agreement as a final remedy-and for non individuals determines residency by place of effective management.
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