Adv. Doron Levy unravels the complexities of a scenario involving a resident of one country managing business activities in another country: “A resident of Israel who manages business activities in Britain is subject to tax in Israel for all his activities anywhere in the world. However, when he is in Britain, he is considered a foreign resident there. Nevertheless, since the activities occur in Britain, he will also be subject to taxes in Britain”.
Enter the realm of double taxation avoidance agreements designed to address the predicament of taxing a transaction in two countries simultaneously. Adv. Levy emphasizes the importance of first determining a person’s country of residence, highlighting the potential challenge of dual residency. He elaborates: “Double taxation agreements deal with this too and are intended to resolve situations in which a person is considered a resident of two countries”.
