Tax residence rules use permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement to resolve dual residency. For treaty purposes, a resident is any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on source based income or capital. Dual residency for individuals is resolved by tie breaker rules in sequence: permanent home, centre for vital interests, habitual abode, nationality, and, if unresolved, mutual agreement between competent authorities. Dual residency for entities is resolved by the place of effective management.
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 residence rules use permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement to resolve dual residency.
For treaty purposes, a resident is any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on source based income or capital. Dual residency for individuals is resolved by tie breaker rules in sequence: permanent home, centre for vital interests, habitual abode, nationality, and, if unresolved, mutual agreement between competent authorities. Dual residency for entities is resolved by the place of effective management.
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