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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== The OECD Model Convention provides: :1. For the purposes of this Convention, 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. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. :2. Where by reason of the provisions of paragraph 1 an individual is a resident of both Contracting States, then his status shall be determined as follows: :a) he shall be deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident only of the State with which his personal and economic relations are closer (centre of vital interests); :b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident only of the State in which he has an habitual abode; :c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident only of the State of which he is a national; :d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement. :3. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it shall be deemed to be a resident only of the State in which its place of effective management is situated.〔(OECD Model Convention )〕 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「tax residence」の詳細全文を読む スポンサード リンク
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