Resident of a Contracting State: residency tie breaker rules use permanent home, centre of vital interests, habitual abode. The Article defines a resident of a Contracting State as any person liable to tax there under domestic criteria such as domicile, residence, place of ... Summary
Resident of a Contracting State: residency tie breaker rules use permanent home, centre of vital interests, habitual abode.
The Article defines a resident of a Contracting State as any person liable to tax there under domestic criteria such as domicile, residence, place of management or registered office. For individuals resident in both Contracting States, residency is resolved by: permanent home, then centre of vital interests if homes exist in both States, then habitual abode, and finally by mutual agreement of the competent authorities; dual residency of non individuals is settled by mutual agreement.
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