Tax residence tie-breaker allocates individual residency by permanent home, centre of vital interests, habitual abode, nationality. The Agreement defines resident of a Contracting State by each State's taxation laws. For individuals resident in both States a tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non individuals resident in both States, residency is determined by 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 tie-breaker allocates individual residency by permanent home, centre of vital interests, habitual abode, nationality.
The Agreement defines resident of a Contracting State by each State's taxation laws. For individuals resident in both States a tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement by competent authorities. For non individuals resident in both States, residency is determined by the place of effective management.
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