Residence tie-breaker rules determine taxable residency by permanent home, center of vital interests, habitual abode, nationality, or mutual agreement. For DTAA purposes a resident of a Contracting State is any person liable to tax there under domestic law. If an individual is resident in both States, residency is determined by: permanent home, centre of vital interests, habitual abode, nationality, and, failing those tests, mutual agreement of the competent authorities. For persons other than individuals who are resident of both States, residency is determined by the State of the entity's place of effective management, or otherwise by mutual agreement of the competent authorities.
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 taxable residency by permanent home, center of vital interests, habitual abode, nationality, or mutual agreement.
For DTAA purposes a resident of a Contracting State is any person liable to tax there under domestic law. If an individual is resident in both States, residency is determined by: permanent home, centre of vital interests, habitual abode, nationality, and, failing those tests, mutual agreement of the competent authorities. For persons other than individuals who are resident of both States, residency is determined by the State of the entity's place of effective management, or otherwise by mutual agreement of the competent authorities.
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