Tax treaty resident definition and tie-breaker rules determine which State is treaty resident for individuals and entities. The Convention defines resident of a Contracting State as any person liable to tax there by domicile, residence, place of management or similar criteria, including State and governmental bodies, with partnerships and estates included only to the extent their income is taxed as that of a resident. Dual resident individuals are subject to sequential tie breaker rules-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-while dual resident non individuals are resident where their place of effective management is situated, or otherwise by mutual agreement.
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 treaty resident definition and tie-breaker rules determine which State is treaty resident for individuals and entities.
The Convention defines resident of a Contracting State as any person liable to tax there by domicile, residence, place of management or similar criteria, including State and governmental bodies, with partnerships and estates included only to the extent their income is taxed as that of a resident. Dual resident individuals are subject to sequential tie breaker rules-permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement-while dual resident non individuals are resident where their place of effective management is situated, or otherwise by mutual agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
