Resident definition under tax treaty governs residency and tiebreaker rules for individuals and entities across contracting states The provision defines resident of a Contracting State as any person liable to tax in that State by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. Dual resident individuals are assigned residence by tie breaker rules: centre of vital interests, habitual abode, nationality, then mutual agreement of competent authorities. Dual resident non individuals are resolved by mutual agreement considering place of effective management and place of incorporation; absent agreement, treaty relief is unavailable except as competent authorities may decide.
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.
Resident definition under tax treaty governs residency and tiebreaker rules for individuals and entities across contracting states
The provision defines resident of a Contracting State as any person liable to tax in that State by domicile, residence, place of management or similar criteria, excluding those taxable only on source income. Dual resident individuals are assigned residence by tie breaker rules: centre of vital interests, habitual abode, nationality, then mutual agreement of competent authorities. Dual resident non individuals are resolved by mutual agreement considering place of effective management and place of incorporation; absent agreement, treaty relief is unavailable except as competent authorities may decide.
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