Residence determination rules govern dual residency tie-breakers prioritising permanent home, centre of vital interests and place of management. The Convention defines a resident as any person liable to tax by domicile, residence, place of management or similar criteria. For individuals with dual residence a hierarchical tie-breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non-individuals, dual residence is resolved by the location of the entity's 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.
Residence determination rules govern dual residency tie-breakers prioritising permanent home, centre of vital interests and place of management.
The Convention defines a resident as any person liable to tax by domicile, residence, place of management or similar criteria. For individuals with dual residence a hierarchical tie-breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non-individuals, dual residence is resolved by the location of the entity's place of effective management.
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