Tax residence

Definitions of residence for tax purposes vary considerably from jurisdiction to jurisdiction. For individuals, physical presence in a jurisdiction is the main factor. Some jurisdictions also determine residency of an individual by reference to a variety of other factors, such as the ownership of a home or availability of accommodation, family, and financial interests. For companies, some jurisdictions determine the residence of a corporation based on its place of incorporation. Other jurisdictions determine the residence of a corporation by reference to its place of management. Some jurisdictions use both a place-of-incorporation test and a place-of-management test.

Domicile is, in common law jurisdictions, a different legal concept to residence, though the two may lead to the same result.

Residence as defined in double taxation treaties may be different from residence as defined for domestic tax purposes. Tax treaties generally follow the OECD Model Convention.

OECD Model Convention