3.7 Tax Residency


Carlos Protto
lectronic document
Spanish and English
 CIAT August 2023

Contents note:

The CIAT Executive Secretariat invites you to download and read chapter 3.7. Tax Residency, of the Manual for the Control of International Tax Planning, written by Carlos Protto.

The purpose of this chapter is to address the concept of tax residence within the main criteria generally used in domestic legislation and tax treaties. Among the issues it deals with are the tax effects derived from the configuration of residency, both in terms of direct and indirect taxes and certain controversial or unresolved aspects linked to the concept of residence, which introduce a risk of abuse for tax authorities.

Chapter 3.7. is No. 21 published within the framework of the Manual for the Control of International Tax Planning and is available in English and Spanish. The complete Manual has six sections made up of 42 chapters. New chapters will be published soon.

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