Resident status determines treaty taxation and is resolved by permanent home, centre of vital interests, or habitual abode. Definition of resident of a Contracting State means any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income from sources in that State. For dual residents, individuals are allocated residency by permanent home, centre of vital interests, habitual abode, and failing those tests by mutual agreement of competent authorities; non individual dual residency is settled by mutual agreement considering place of incorporation and 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 determines treaty taxation and is resolved by permanent home, centre of vital interests, or habitual abode.
Definition of resident of a Contracting State means any person liable to tax in that State by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on income from sources in that State. For dual residents, individuals are allocated residency by permanent home, centre of vital interests, habitual abode, and failing those tests by mutual agreement of competent authorities; non individual dual residency is settled by mutual agreement considering place of incorporation and place of effective management.
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