Resident status rules determine tax residency via permanent home, centre of vital interests, habitual abode or management. The Convention defines resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on in state sourced income or capital. Dual residency for individuals is resolved by tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and ultimately mutual agreement. Dual residency for entities is resolved by the place of effective management, with unresolved cases settled 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 residency via permanent home, centre of vital interests, habitual abode or management.
The Convention defines resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on in state sourced income or capital. Dual residency for individuals is resolved by tie breakers: permanent home, centre of vital interests, habitual abode, nationality, and ultimately mutual agreement. Dual residency for entities is resolved by the place of effective management, with unresolved cases settled by mutual agreement of the competent authorities.
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