Residence tiebreaker rules determine which State is the residence for dual residents under the tax treaty. The provision defines resident as any person liable to tax in a Contracting State by domicile, residence, place of management or similar criteria and sets ... Summary
Residence tiebreaker rules determine which State is the residence for dual residents under the tax treaty.
The provision defines resident as any person liable to tax in a Contracting State by domicile, residence, place of management or similar criteria and sets tie breaking rules: for individuals, priority is given to permanent home, then centre of vital interests, then habitual abode, then nationality, with unresolved cases settled by mutual agreement of competent authorities; for non individuals, residence is determined by place of effective management.
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