Fiscal domicile rules determine residency and tiebreakers for individuals, with mutual agreement and management test for entities. Article 4 defines a resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria. For individuals resident in both States, tie breakers are: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement between 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.
Fiscal domicile rules determine residency and tiebreakers for individuals, with mutual agreement and management test for entities.
Article 4 defines a resident as a person liable to tax by reason of domicile, residence, place of management or similar criteria. For individuals resident in both States, tie breakers are: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement between competent authorities. For non individuals resident in both States, residency is determined by the place of effective management.
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