Resident determination rules establish tie breaker hierarchy to resolve dual residency for individuals and entities under tax conventions. Residency for tax purposes is based on liability to tax under domestic criteria; individuals dual resident are resolved by a hierarchical tie breaker-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and non individual dual residency is resolved by place of effective management or, if indeterminate, 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.
Resident determination rules establish tie breaker hierarchy to resolve dual residency for individuals and entities under tax conventions.
Residency for tax purposes is based on liability to tax under domestic criteria; individuals dual resident are resolved by a hierarchical tie breaker-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-and non individual dual residency is resolved by place of effective management or, if indeterminate, by mutual agreement of competent authorities.
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