Tax residence rules: hierarchical tie breaker determines residency for dual residents and place of effective management governs entities. The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income. For individuals with dual residence, a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non-individuals with dual residence, residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities.
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Provisions expressly mentioned in the judgment/order text.
Tax residence rules: hierarchical tie breaker determines residency for dual residents and place of effective management governs entities.
The Convention defines a resident of a Contracting State as any person liable to tax there by reason of domicile, residence, place of management or similar criteria, excluding those taxable only on domestic-source income. For individuals with dual residence, a hierarchical tie breaker applies: permanent home, centre of vital interests, habitual abode, nationality, and failing these, mutual agreement of competent authorities. For non-individuals with dual residence, residence is determined by place of effective management, or otherwise by mutual agreement of the competent authorities.
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