Double Tax Treaties Flashcards
1
Q
What are the 4 tests
A
- Permanent Home test
- Center Vital Interests Test
- Habitual Abode test
- Ultimate tie breaker
2
Q
Permanent home test
A
Accommodation is arranged for permanent use
Not PPOA
3
Q
Center Vital INterest test
A
If a permanent home in both states
Consider:
- family, occupation, cultural activities political, place of business
4
Q
Habitual abode test
A
Where does the individual spend most of there time during the relevant period?
5
Q
Ultimate tie breaker
A
Residence determined by nationality or citizenship.
otherwise maybe double taxed
6
Q
Dual Resident Company tie breaker
A
Where is the place of effective management?
- Where key, necessary decisions for conduct of the business are in substance made.
