Resident status tie-breaker rules determine which state treats an individual or entity as resident for tax treaty purposes. The provision defines resident of a Contracting State by domestic law and provides hierarchical tie-breaker rules for dual-resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and for non-individuals assigns residence to the State of the entity's 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.
Resident status tie-breaker rules determine which state treats an individual or entity as resident for tax treaty purposes.
The provision defines resident of a Contracting State by domestic law and provides hierarchical tie-breaker rules for dual-resident individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and for non-individuals assigns residence to the State of the entity's place of effective management.
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