Tax residence determination: tie breaker rules allocate dual residence by permanent home, centre of vital interests, habitual abode, nationality. The Convention defines resident of a Contracting State as anyone liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on local-source income or local capital. For individuals who are residents of both States, a tie breaker hierarchy applies: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Non individual dual residents are deemed residents of the State of their 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.
Tax residence determination: tie breaker rules allocate dual residence by permanent home, centre of vital interests, habitual abode, nationality.
The Convention defines resident of a Contracting State as anyone liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on local-source income or local capital. For individuals who are residents of both States, a tie breaker hierarchy applies: permanent home; centre of vital interests; habitual abode; nationality; and, if unresolved, mutual agreement by competent authorities. Non individual dual residents are deemed residents of the State of their place of effective management.
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