Tax residence criteria and tie breaker rules determine which State treats a person as resident under the treaty. Defines resident of a Contracting State as persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. For dual resident individuals a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For dual resident non individuals residence is determined by place of effective management, with unresolved cases settled by 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 residence criteria and tie breaker rules determine which State treats a person as resident under the treaty.
Defines resident of a Contracting State as persons liable to tax by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. For dual resident individuals a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement by competent authorities. For dual resident non individuals residence is determined by place of effective management, with unresolved cases settled by mutual agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
