Residence tie breaker rules determine treaty residency by permanent home, centre of vital interests, habitual abode, nationality. The Convention defines resident as any person liable to taxation in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria. Where an individual is resident of both Contracting States, treaty residency is determined by tie breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between competent authorities; persons other than individuals with dual residency are resolved 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.
Residence tie breaker rules determine treaty residency by permanent home, centre of vital interests, habitual abode, nationality.
The Convention defines resident as any person liable to taxation in a Contracting State by domicile, residence, place of incorporation, place of management or similar criteria. Where an individual is resident of both Contracting States, treaty residency is determined by tie breaker rules: permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between competent authorities; persons other than individuals with dual residency are resolved by mutual agreement.
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