Resident status determination uses permanent home and centre of vital interests to resolve dual residency issues. Defines resident as any person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on source income. For dual resident individuals, residence is determined by: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement. For non individuals, residence is where the place of effective management is situated, with doubts settled by mutual agreement.
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Provisions expressly mentioned in the judgment/order text.
Resident status determination uses permanent home and centre of vital interests to resolve dual residency issues.
Defines resident as any person liable to tax by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on source income. For dual resident individuals, residence is determined by: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement. For non individuals, residence is where the place of effective management is situated, with doubts settled by mutual agreement.
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