yes I know... And DTAs don't do that... all DTA does is prevent double taxation on the same money.. Hence my previous comment you can be tax resident in multiple jurisdictions at the same time
A DTA doesn't determine what is or isn't asseable income
And as I have said the 180 rule isnt worldwide in every country. As a rule to tax residency
nope. As I said you can be tax resident in multiple jurisdictions...and that's the purpose of DTAs if you can only be tax resident under one jurisdiction as you infer there is no need for any DTAs is there βπ
Now if your income wasn't taxed at source, and you are under two jurisdictions then yes the second one could take the full wack
The concept is called taxed at source.
I have been under 3 tax jurisdictions at one point and the source of the income gets first bite and the tax credits against other two jurisdictions
BTW and not every country in the world uses 180 days as a tax residency rule either
nope not true, as you can be tax resident in multiple jurisdictions at the same time, therefore the test under who gets first bite is the source of income.. Been there got the t-shirt π