Tax residence determination: hierarchical tie breaker for individuals and place of effective management for entities governs dual residency. Resident for treaty purposes means a person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income. Dual residency for individuals is resolved by a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non individuals, residence is determined by place of effective management, or otherwise by mutual agreement of competent authorities.
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 determination: hierarchical tie breaker for individuals and place of effective management for entities governs dual residency.
Resident for treaty purposes means a person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on in state source income. Dual residency for individuals is resolved by a hierarchical tie breaker: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non individuals, residence is determined by place of effective management, or otherwise by mutual agreement of competent authorities.
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