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.
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.
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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