Fiscal domicile rules determine treaty residence using permanent home, centre of vital interests, habitual abode and nationality. Defines resident of a Contracting State as any person liable to taxation there by domicile, residence, place of management or similar criterion. For individuals resident in both States, a hierarchy determines residence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. For non individuals resident in both States, residence 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 treaty residence using permanent home, centre of vital interests, habitual abode and nationality.
Defines resident of a Contracting State as any person liable to taxation there by domicile, residence, place of management or similar criterion. For individuals resident in both States, a hierarchy determines residence: permanent home, centre of vital interests, habitual abode, nationality, and failing those, mutual agreement. For non individuals resident in both States, residence is determined by the place of effective management.
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