Fiscal domicile rules determine single-state tax residency by permanent home, center of vital interests, habitual abode, nationality. Article 4 defines fiscal domicile for treaty purposes and provides hierarchical tie breaker rules for dual residency: for individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement; for companies-State of nationality, then place of effective management; for other persons-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.
Fiscal domicile rules determine single-state tax residency by permanent home, center of vital interests, habitual abode, nationality.
Article 4 defines fiscal domicile for treaty purposes and provides hierarchical tie breaker rules for dual residency: for individuals-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement; for companies-State of nationality, then place of effective management; for other persons-place of effective management.
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