Tax residency tie breaker rules determine which state a person is resident of for tax purposes under the DTAA. Article 4 defines resident of a Contracting State as any person liable to tax in that State and resolves dual residency for individuals by a tiered test: ... Summary
Tax residency tie breaker rules determine which state a person is resident of for tax purposes under the DTAA.
Article 4 defines resident of a Contracting State as any person liable to tax in that State and resolves dual residency for individuals by a tiered test: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement of competent authorities; for non individuals residency is determined by place of effective management.
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