Residence tie-breaker rules determine tax residency by permanent home, centre of vital interests, habitual abode, nationality. The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxable only on domestic-source income. For individuals with dual residency a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases settled by 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 tax residency by permanent home, centre of vital interests, habitual abode, nationality.
The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management, place of incorporation or similar criteria, excluding persons taxable only on domestic-source income. For individuals with dual residency a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For non individuals with dual residency, residency is determined by the place of effective management, with unresolved cases settled by mutual agreement.
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