Residence determination rules: tie breaker criteria establish exclusive tax residence and management based residence for entities. Defines resident of a Contracting State as any person taxable there under domicile, residence, place of management or similar criteria. For individuals ... Summary
Residence determination rules: tie breaker criteria establish exclusive tax residence and management based residence for entities.
Defines resident of a Contracting State as any person taxable there under domicile, residence, place of management or similar criteria. For individuals resident in both States, exclusive residence is determined by: permanent home availability; centre of vital interests if homes exist in both States; habitual abode if centre of vital interests cannot be determined; nationality if habitual abode is inconclusive; and, failing all, mutual agreement of competent authorities. For non individuals resident in both States, residence is determined by the location of the place of effective management.
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