Tax residence determination: sequential tie breaker rules govern dual residency and place of effective management decides entities. The Agreement defines resident of a Contracting State as any person liable to tax there under domestic law. For individuals resident of both States, residence is determined by: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement between competent authorities. For persons other than individuals who are residents of both States, residence is determined by the location of the 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 residence determination: sequential tie breaker rules govern dual residency and place of effective management decides entities.
The Agreement defines resident of a Contracting State as any person liable to tax there under domestic law. For individuals resident of both States, residence is determined by: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement between competent authorities. For persons other than individuals who are residents of both States, residence is determined by the location of the place of effective management.
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