Residence tie-breaker rules determine treaty residency by permanent home, centre of vital interests, habitual abode, nationality. The term resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxed only on income from local sources. For dual resident individuals the treaty applies a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement if needed. For dual resident entities residency is determined by place of effective management, with unresolved cases to be settled by the competent authorities through mutual agreement.
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 treaty residency by permanent home, centre of vital interests, habitual abode, nationality.
The term resident of a Contracting State means any person liable to tax there by domicile, residence, place of management or similar criterion, excluding those taxed only on income from local sources. For dual resident individuals the treaty applies a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement if needed. For dual resident entities residency is determined by place of effective management, with unresolved cases to be settled by the competent authorities through mutual agreement.
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