Tax residency tie breaker: rules determine resident state via permanent home, centre of vital interests, habitual abode, nationality. Definition of resident hinges on ordinary residence, domicile, and for companies place of effective management or incorporation. Dual individual residency is resolved by a sequential tie breaker: permanent home (then centre of vital interests), habitual abode, nationality, and finally mutual agreement. For non individuals, place of effective management determines residency, with residual doubts settled by mutual agreement of competent authorities.
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.
Tax residency tie breaker: rules determine resident state via permanent home, centre of vital interests, habitual abode, nationality.
Definition of resident hinges on ordinary residence, domicile, and for companies place of effective management or incorporation. Dual individual residency is resolved by a sequential tie breaker: permanent home (then centre of vital interests), habitual abode, nationality, and finally mutual agreement. For non individuals, place of effective management determines residency, with residual doubts settled by mutual agreement of competent authorities.
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