Resident status tie breaker rules determine tax residence by permanent home, centre of vital interests, habitual abode, nationality. Determination of resident of a Contracting State depends on domestic tax liability criteria and excludes persons 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 of competent authorities. For dual resident non individuals residence is the State of the place of effective management, with unresolved cases referred to 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.
Resident status tie breaker rules determine tax residence by permanent home, centre of vital interests, habitual abode, nationality.
Determination of resident of a Contracting State depends on domestic tax liability criteria and excludes persons 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 of competent authorities. For dual resident non individuals residence is the State of the place of effective management, with unresolved cases referred to mutual agreement.
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