Territorial scope
Personal scope
What is the territorial scope of the Taxation Convention?
The Taxation Convention applies to Austria and Canada in the geographical sense.
What is the personal scope of the Taxation Convention?
The scope of the Convention is determined by a person's place of residence. It applies to residents of one or both of the Contracting States, whoare liable for taxation due to domicile, residence, or similar attribute. Should a person be a resident of both Contracting States, the State of residence should be the one in which the person holds his/her permanent residence. If the person has a residence in both States, or in neither of them, the State of residence should be the one in which the person holds the tighter personal and/or commercial ties (center of vital interests).
Relevant Links:
Determination of residency status: http://www.cra-arc.gc.ca/tx/nnrsdnts/ndvdls/nnrs-eng.html




