Tax residence tie breaker rules determine which State treats an individual or entity as resident for tax purposes. Resident is any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding persons ... Summary
Tax residence tie breaker rules determine which State treats an individual or entity as resident for tax purposes.
Resident is any person liable to tax in a Contracting State by reason of domicile, residence, place of management or similar criteria, excluding persons taxable only on local-source income; governments and their subdivisions are residents. For individuals resident in both States a tie breaker sequence applies: permanent home, centre of vital interests, habitual abode, nationality, and if unresolved, mutual agreement by competent authorities. For non-individuals resident in both States, residence is the State of the place of effective management.
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