Tax residency rules determine treaty residence by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement. The Article defines resident of a Contracting State as a person liable to tax there by criteria such as domicile, residence or place of management, excluding persons taxable only on in state income or capital. For dual resident individuals, residence is determined by: permanent home availability; centre of vital interests; habitual abode; nationality; or mutual agreement if still unresolved. For non individuals resident in both States, residence is determined by the location of the 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 residency rules determine treaty residence by permanent home, centre of vital interests, habitual abode, nationality, or mutual agreement.
The Article defines resident of a Contracting State as a person liable to tax there by criteria such as domicile, residence or place of management, excluding persons taxable only on in state income or capital. For dual resident individuals, residence is determined by: permanent home availability; centre of vital interests; habitual abode; nationality; or mutual agreement if still unresolved. For non individuals resident in both States, residence is determined by the location of the place of effective management.
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