Fiscal domicile rules determine treaty residency using hierarchical tie breaker tests, with mutual agreement for unresolved dual residency. The Convention defines resident of a Contracting State by domestic taxation criteria and provides hierarchical tie breaker rules: for individuals, determine permanent home, centre of vital interests, habitual abode, nationality, and if unresolved, mutual agreement by competent authorities; for non-individuals, residency is based on the place of effective management, with doubts to be 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.
Fiscal domicile rules determine treaty residency using hierarchical tie breaker tests, with mutual agreement for unresolved dual residency.
The Convention defines resident of a Contracting State by domestic taxation criteria and provides hierarchical tie breaker rules: for individuals, determine permanent home, centre of vital interests, habitual abode, nationality, and if unresolved, mutual agreement by competent authorities; for non-individuals, residency is based on the place of effective management, with doubts to be settled by mutual agreement.
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