Tax residency tie breaker rules determine which state taxes an individual or entity based on home, habitual abode, and management. Determination of resident status under the DTAA is based on domestic liability to tax, with dual residency for individuals resolved by sequential tie breakers: permanent home, economic relations concentration where both permanent homes exist, habitual abode if no permanent home, then economic activity concentration if habitual abode is indecisive, and mutual agreement by competent authorities if unresolved; for non individuals residence is the State of 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.
Tax residency tie breaker rules determine which state taxes an individual or entity based on home, habitual abode, and management.
Determination of resident status under the DTAA is based on domestic liability to tax, with dual residency for individuals resolved by sequential tie breakers: permanent home, economic relations concentration where both permanent homes exist, habitual abode if no permanent home, then economic activity concentration if habitual abode is indecisive, and mutual agreement by competent authorities if unresolved; for non individuals residence is the State of place of effective management.
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