n Tax Breaks Newsletter - A South African perspective on resolving dual residence disputes : international tax

Volume 2016, Issue 361
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MULTINATIONAL COMPANIES may find they are simultaneously resident in two countries under the domestic laws of each of the countries in which they have effective management. Modern tax treaties contain tie-breaker rules to determine dual residence in these circumstances. The tiebreaker rule is essentially a test that enables the company to determine residency for tax purposes.

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