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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Soviet Union: double taxation agreement, Article 4: Residence for tax purposes

(1) Where by reason of the provisions of sub-paragraph (e) of paragraph (1) of Article 3 an individual is deemed to be a resident of both Contracting States, then his status shall be determined in accordance with the following rules:
(a) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both Contracting States, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests);
(b) if the Contracting State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either Contracting State, he shall be deemed to be a resident of the Contracting State in which he has an habitual abode;
(c) if he has an habitual abode in both Contracting States or in neither of them, he shall be deemed to be a resident of the Contracting State of which he is a national;
(d) if each Contracting State regards him as a national of that State or if he is a national of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement.
(2) Where by reason of the provisions of sub-paragraph (e) of paragraph (1) of Article 3 a person other than an individual is deemed to be a resident of both Contracting States, then it shall be deemed to be a resident of the Contracting State in which its place of effective management is situated.