miércoles, 18 de mayo de 2011
DUAL RESIDENCE
According to the updated Commentary on Art. 4 of the OECD Model, a person who, under the domestic laws of States A and B, is a residente of both states but who, under the tas treaty between States A and B, is a resident only of State A cannot, as a domestic law resident of State B, have access to a tax treaty between State B and a third state from which he derives income.
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For the purposes of the Convention OECD the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof.
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