Tax residency rules determine residence via permanent home, centre of vital interests and other tie breakers under a tax treaty. The Article defines resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income or capital from sources in that State. Dual resident individuals are subject to sequential tie breakers: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Dual resident entities are deemed resident where their place of effective management is situated, with unresolved cases referred to competent authorities for 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.
Tax residency rules determine residence via permanent home, centre of vital interests and other tie breakers under a tax treaty.
The Article defines resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income or capital from sources in that State. Dual resident individuals are subject to sequential tie breakers: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Dual resident entities are deemed resident where their place of effective management is situated, with unresolved cases referred to competent authorities for mutual agreement.
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