Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Double taxation treaty defines resident status based on domicile, management location, and vital interests for tax purposes</h1> Article 4 of the Double Taxation Avoidance Agreement between contracting states defines 'resident' as any person liable to tax in a state due to domicile, residence, place of management, or similar criteria. For individuals who are residents of both states, residency is determined by permanent home availability, center of vital interests, habitual abode, nationality, or mutual agreement by competent authorities. For entities that are residents of both states, competent authorities determine residency considering effective management location, incorporation place, and other relevant factors through mutual agreement.
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