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, ... Summary
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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